A. OWNERSHIP/ADVISORY HISTORY Schwallier Wealth Management LLC (“the Adviser”) DBA Schwallier Wealth Management was established as a Michigan Limited Liability Company in April 2007. It was subsequently registered as an SEC-registered investment adviser. The Adviser’s current owner is Adam Schwallier (“Mr. Schwallier”). B. ADVISORY SERVICES OFFERED The Adviser’s services include portfolio management services, institutional retirement advisory service, and the creation of financial plans for clients. The Adviser will meet with a client to evaluate the individual client’s investment needs, goals and objectives. After the evaluation, the Adviser may recommend one or several of the services described below. iv. FINANCIAL PLANNING The Adviser offers clients financial planning services to evaluate their financial situation, goals and risk tolerance. Through a series of personal interviews and the use of questionnaires, the Adviser will collect pertinent data, identify goals, objectives, financial problems, potential solutions, prepare specific recommendations and implement recommendations. As a result of these actions, the Adviser’s advice may be provided on financial and cash management, risk management, financial issues relating to divorce or marital issues, estate planning, tax issues, IRA distribution planning, Investment Planning/Asset Allocation, retirement planning, educational funding, goal setting, or other needs as identified by the client and Advisor. The Adviser may offer broad-based planning services, or the client may desire advice on certain planning components; the Adviser can tailor services as desired by the client. At the conclusion of the Financial Planning Service, the Adviser will present the client with the financial plan. ii. FIXED FEE FINANCIAL PLANNING The Adviser may provide financial planning services on a fixed fee basis. This service involves working one-on-one with an Advisor over an extended period of time by paying the annual fee on either a monthly, quarterly, or yearly, or hourly basis, as elected by the client. The client will have access to a planner who will work with them to design their plan. The planner will monitor the plan, recommend any changes, and ensure the plan is up to date for the duration of the engagement. Upon desiring a comprehensive plan, a client will be taken through establishing their goals and values around money. The Adviser may charge for the creation of the plan and the requisite implementation. Financial planning engagements begin with the creation of a personalized plan that includes the establishment of goals and objectives. Financial planning services charged via a fixed fee may be broad- based or narrowly focused, depending on the client’s needs. For clients engaged in ongoing planning services (non-hourly Clients) the Adviser will proactively schedule and complete a periodic review of each personalized plan to make updates and adjust for life changes. Each client engaged in ongoing planning services receives scheduled communication to conduct periodic reviews of each client’s financial life. These reviews proactively seek to address the Client’s financial life and may cover a wide range of topics including but not limited to: Cash Flow and Debt Management Advisor will regularly review your income and expenses to determine your current surplus or deficit and advise on options for using surplus, or how to reduce expenses if they exceed your income. Advice may also be given on which debts to pay off in which order. Recommendations may be made regarding how to appropriate cash reserves for emergencies and other financial goals, plus strategies to save desired amounts. Risk Management A risk management review analyzes your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the potential cost of not. Employee Benefits We will provide feedback and analysis as to whether you are taking the full advantage of your employee benefit programs. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. Retirement Planning Retirement planning services typically include projections depicting the likelihood of achieving your financial goals, with financial independence usually the primary objective. For situations where projections show less than the desired results, a recommendation may include showing you the impact on those projections by making changes in certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. Tax Planning Strategies Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state, or local tax laws and rates that may impact your situation. Education Planning College funding advice may include analyzing how much will be needed to achieve successful education funding goals, along with savings strategies and the “pros-and-cons” of various college savings vehicles that are available. Investment Consultation Our investment consultation services may provide information on the types of investment vehicles available, employee retirement plans and/or stock options, investment analysis and strategies, asset selection and portfolio design, as well as assisting you with your investment account if it is maintained at another broker/dealer or custodian. Other than Scheduled Review We strongly urge our clients to notify us of any change in their circumstances, and to schedule a review any time there is such a change. An annual review will be conducted even in the event of no substantial change, because tax laws, estate laws, and investment vehicles are always changing. iii. PORTFOLIO MANAGEMENT The Adviser’s portfolio management engagement with a client will include, as appropriate, the following:
• Providing assistance in reviewing the client’s current investment portfolio against the client’s personal and financial circumstances as disclosed to the firm in response to a questionnaire and/or in discussions with the client and reviewed in meetings.
• Analyzing the client’s financial circumstances, investment holdings and strategy, and goals.
• Providing assistance in identifying a targeted asset allocation and portfolio design.
• Implementing and/or recommending an appropriate investment portfolio.
• Implementing changes in the client’s investment portfolio in consideration of changes in the client’s personal circumstances, investment objectives, and tolerance for risk,

the performance record of any of the client’s investments, and/or the performance of any fund retained by the client, as well as based on changing economic and market outlooks. With non-discretionary portfolio management services, prior to the execution of any trades, the Adviser will telephone the client to receive his/her authorization. Upon receiving the client’s authorization, the Adviser will execute the trade per his/her instructions. iv. INSTITUTIONAL RETIREMENT INVESTMENT ADVISORY SERVICES The Adviser also provides investment consulting and investment advisory services to institutional ERISA and non-ERISA retirement plans. Institutional investment management services typically include portfolio design, preparation of investment policy statements, screening of investment selections, and performance monitoring. Employees in qualified retirement plans are protected by the Employee Retirement Income Security Act of 1974 (ERISA), which requires employers, investment advisors, and plan administrators to put employees’ interests first when managing retirement savings plans. Public retirement systems are governed by similar state laws and often incorporate the protections of ERISA. In order to demonstrate that a plan fiduciary has operated in a prudent manner, there are certain steps that the fiduciary must take. The Adviser is committed to helping fiduciaries understand their roles and to assist them in implementing a process that allows them to fulfill their duties and responsibilities. The Adviser will assist plan fiduciaries in the following: Investment Selection and Monitoring ● Creating an investment policy statement ● Screening investment selections ● Monitoring the investment options against well-defined risk and return criteria Plan Evaluation/Benchmarking The Adviser also “benchmarks” retirement plans against those of organizations in the same industry and against national “industry” data. Factors that are used to evaluate retirement plans include the following: ● Participation, deferral percentage, and asset allocation ● Investment performance ● Plan design ● Total plan costs ● Recordkeeping and administration ● Participant education and communication ● Technology ● Service provider capabilities and profiles Vendor Search and Plan Implementation The Adviser will also assist its retirement plan clients in selecting trustees, custodians, actuaries, and other service providers. This process involves: ● Generating criteria to identify appropriate service providers ● Developing requests for proposals ● Objectively rating service providers ● Evaluating highly rated service provider candidates Once a service provider is selected, the Adviser will assist a client in implementing the client’s retirement plan program. In implementing the program, the Adviser will, among other things, review the plan design, develop performance standards, and review the service provider’s contract. v. Participant Account Management (Discretionary) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform 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 an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Employee Education The Adviser works with corporations to provide financial educational services to the company’s employees. The Adviser will provide on-site visits to companies to help their employees with their individual financial situations. The Adviser provides group seminars and individual meetings. The topics covered include but are not limited to budgeting, financial planning, risk tolerance, asset allocation, and retirement projections. 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 interests;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. vi. Professional Trustee Services Certain Individual Advisor Representatives of the firm are qualified to act as Professional Trustees at an Individual Trustee level. Neither the firm nor any IAR’s shall act in the capacity of a Corporate Trustee. The IARs authorized to act as Individual Professional Trustees may offer comprehensive services related to the duties of a Trustee that may include the following:
• Determination of eligible withdrawals in accordance with the written Trust document
• Collaboration with the Estate Planning Attorney regarding income withdrawal needs for the sake of Trust document creation, or modification
• Payment of bills and cashflow management
• Reconciliation of assets, liabilities, insurance policies, or annuities
• Execution of estate upon death
• Distribution of estate upon beneficiary attained age
• Oversight of tax return completion (third party CPA firm will actually execute the tax return) C. TAILORED SERVICES As described above, the Adviser’s services are individualized to each client. Portfolio management clients may impose restrictions on investment in certain securities or types of securities. All restrictions must be presented to the Adviser in writing. D. WRAP PROGRAM The Adviser has a wrap fee program through LPL. Please see Appendix 1 for more information. E. CLIENT ASSETS MANAGED As of March 25, 2024, SCHWALLIER WEALTH MANAGEMENT manages $143,657,128 in client assets of which $141,556,537 was managed on a discretionary basis and $2,100,591 was managed on a non-discretionary basis.