5 disregard the advice your Adviser Representative provides. Normally, after a financial review of your current financial condition, objectives and risk tolerance levels, your Adviser Representative will recommend a portfolio allocation based on model portfolios SWM maintains that are tailored to certain risk appetites. Should you decide to accept the recommended asset allocation within a particular model portfolio, your Adviser Representative will select from an approved list of investments, registered mutual funds, exchange-traded funds (ETFs) or Undertakings for the Collective Investment of Transferable Securities (UCITS) that conform to the recommended asset allocation and present these for your consideration and approval. You are free to accept these recommendations or request the selection of other funds from the approved list.At least once annually, if not more frequently, your Adviser Representative will review the performance of the portfolio along with other aspects of your financial situation in order to determine whether any changes should be considered. Your Adviser Representative recommends any such changes to you. You may then decide whether to authorize that these changes be implemented or request the selection of other funds from the approved list. UK Pension Transfer Services After moving to the United States, many UK expatriates maintain assets in defined benefit or defined contribution pension accounts that they had established while living and working in the United Kingdom. These assets are kept under arrangements with their former employers that involve the use of institutional trustees to safe-keep and administer the assets. Over the years, SWM has found that many of these expatriates desire better arrangements that afford them more flexibility to manage their pension plan assets while they are living and working in the United States. Pension legislation in the United Kingdom has made it possible for UK expatriates to transfer their pension assets to certain approved personal pension schemes so that they can manage those assets on a more flexible basis going forward. The two principal schemes that have been developed for this purpose are the self-invested personal pension plan or SIPP, and the qualified recognized overseas pension scheme or QROPS. SWM helps you, as a UK expatriate, to assess whether a transfer might be in your best interest. SWM has established a process to elicit the right information in order to help you make this decision and to discuss the options that might be available to you. Once a transfer decision has been made, the Adviser Representative who has been selected as your financial professional will request a statement of value from your existing pension trustee. If suitable and in conjunction with a review conducted by an independent Financial Conduct Authority-regulated adviser, the Adviser Representative will assist with the transfer to a SIPP. In 2017, legislative changes in the United Kingdom made it disadvantageous for individuals to transfer into a QROPS. Because of these changes, SWM no longer recommends the transfer of UK pension assets into QROPS. SWM, however, will provide investment management services for a QROPS if a client confers non- discretionary investment management authority to SWM for managing this account. An Adviser Representative may recommend that you transfer your pension assets to a SIPP if it is determined that such a transfer would be in your best interest. SIPPs come with certain investment restrictions that are made clear to you in the course of establishing the account, and they are offered by a number of providers that have been reviewed and approved by SWM. The assets in a SIPP are administered by a FCA-regulated pension trustee, and a custodian selected by you, the client, provides custody services for these assets. A separate agreement among the trustee, the custodian and you establishes the terms and conditions under which these services are provided to you. Financial Planning Services SWM offers a continuous and collaborative financial planning process to its clients. After a full discussion with you about your financial circumstances, which may include a review of your assets, liabilities, income and expenses as well as your future estate and retirement planning goals, your Adviser Representative will produce a comprehensive financial plan for your review. Your Adviser Representative will typically review investments that may be held in various qualified retirement accounts, including individual retirement accounts (IRAs) or 401(k) accounts and non-qualified accounts. Along with any US assets you have, your Adviser Representative will consider any foreign assets you may also own, such as foreign pensions, or investment accounts. SWM believes that global assets are an integral part of an overall financial picture and need to be taken into consideration when looking at a holistic retirement plan. In the course of designing a financial plan, SWM may enlist the assistance of third parties that are specialists in various disciplines, such as tax and estate planning. SWM does not charge a fee or receive any other compensation or benefit for referring clients to these specialists. As a client, you are free to make your own arrangements with these specialists on terms that are acceptable to you. The complexities posed by various inheritance and trust laws in various jurisdictions can make estate planning challenging. Your Adviser Representative can recommend the services of a number of independent solicitors who specialize in estate and inheritance tax planning and are familiar with the cross-border considerations many individuals face. In addition, individual US states have varying tax treatment of different types of income. Therefore, having an attorney who understands the state rules as well can be very helpful. SWM does not charge a fee or receive any other compensation or benefit for referring clients to these specialists. For clients whose financial plan focuses around UK pension assets, SWM has identified a number of trust and product providers that have established tax friendly structures to facilitate the transfer of these assets in the most tax effective manner. Likewise, the complexities of living in various jurisdictions demand a very deliberate approach to ensuring that a UK expatriate meets all applicable tax regulations, while at the same time ensuring that transactions, dispositions and transfers of property are structured in the most tax effective manner. Neither SWM nor your Adviser Representative is a tax consultant. Before embarking on any course in which tax plays an important part, therefore, you are advised to seek advice from a CPA or other tax professional familiar with the nuances that can arise from having potential tax exposure in multiple jurisdictions. C. General Considerations Investment recommendations and advice offered by SWM is not considered and should not be considered legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform SWM promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify SWM of any such changes will result in investment recommendations not meeting your needs. SWM tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on investing in certain securities or types of securities. Services will begin with an initial consultation and data gathering. Your Advisory Representative will ask you various questions about your financial situation and request certain documents about your financial accounts. You may be asked to complete a fact finder or data gathering document. The information gathered by SWM will assist SWM to provide you with the requested services and customize the services to your financial situation. Depending on the services you have requested, SWM will gather various financial information and history from you including, but not limited to:
• Retirement and financial goals
• Investment objectives
• Investment horizon
• Financial needs
• Cash flow analysis
• Cost of living needs
• Education needs
• Savings tendencies
• Other applicable financial information required by SWM in order to provide the investment advisory services requested. QROPS and SIPP product providers may be available through other investment advisers under slightly different programs with different fees, charges and restrictions. These should be considered in deciding who you select as your financial advisers and other service providers, including SWM. An external service provider will have separate fee agreements as part of

its service level agreement. These agreements will be provided to you for review and sign-off, at the same time as the appointment of your Adviser Representative and as part of your overall investment management agreement and package with us. IRA Rollover Considerations 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. As part of our consulting and advisory services, we offer you recommendations and advice concerning your employer retirement plan or other qualified retirement account. Our recommendations can include you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA"). Further, we offer our management services be applied to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as described above under Item 5. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer's (former employer's) plan. 2. Move the funds to a new employer's retirement plan. 3. Cash out and taking a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage it is important you understand the following: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans often have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy can have higher risk than the option(s) provided to you in your plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets titled in a 401k or retirement account, you could delay your required minimum distribution beyond age72. (You must take your first required minimum distribution for the year in which you turn age 72 (70 ½ if you reach 70 ½ before January 1, 2020). However, the first payment can be delayed until April 1 of 2020 if you turn 70½ in 2019. If you reach 70½ in 2020, you have to take your first RMD by April 1 of the year after you reach the age of 72. For all subsequent years, including the year in which you were paid the first RMD by April 1, you must take the RMD by December 31 of the year. (Source IRS.gov)) 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. D. SWM does not participate in wrap-fee programs. E. As of January 31st 2024 , SWM managed $ 35,958,062 of client assets on a nondiscretionary basis. While no Advisory Representative can exceed the fees schedules outlined below, each Advisory Representative can negotiate and charge an advisory fee based on the fee schedules below. The amount of the fee is not commensurate with education or tenure in the industry. Therefore, you will find different Advisory Representatives charge more or less than the fee you are being charged for similar services. Your Advisory Representative has a direct interest in the fee charged to you since SWM will pay a portion of the advisory fee charged to you to your Advisory Representative. You will not be charged separate set-up fees or termination fees for services not received. Fees are negotiable and are not based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds. You may make additions to the Account or withdrawals from the Account. Adviser Representatives charge an annual fee shall not to exceed 1.25% annually. The annual fee will begin immediately upon completion of the account funding
• Depending on the provider, fees will be deducted from the account either: 1) quarterly in arrears or 2) monthly in arrears.
• Fees are based on the valuation date of the billing cycle. Therefore, you may pay the full billing period (i.e., month or quarter) regardless of when assets were deposited to your account. Financial Planning Fees for planning services are strictly for planning services. Therefore, you will pay fees for additional services obtained such as asset management. It is your Advisory Representatives discretion whether or not to waive a portion or all of any financial planning or consulting fee if you implement advice through your Advisory Representative and participate in an asset management program or service. Fees are negotiable. Your fees will be dependent on several factors including time spent with the Advisory Representative, number of meetings, complexity of your situation, amount of research, services requested and staff resources, and your Advisory Representative. Service Fee Payable Financial Planning $2,000 - $10,000 A fee payment schedule will be negotiated and agreed upon between you and your Advisory Representative prior services beginning and will be outlined in the client advisory agreement. Fees are: 1. Payable up to one-half (1/2) upon execution of the advisory agreement with Skybound Wealth Management, the balance due at the time of presentation of the plan or recommendations;