A. Description of the Advisory Firm B. Types of Advisory Services our retainer service. This service may be most ideal for young professionals, though we do not limit this service to them. Sparta Wealth Partners offers this comprehensive service to clients that want to focus on financial planning and personal financial preparation. It is charged as an on-going monthly retainer program of an amount negotiated between the client and Sparta Wealth Partners. Initial Onboarding Process for Retainer Services
• Various service levels are offered to provide the most appropriate services for clients based on their needs and goals.
• The Client would complete an Investment Advisory Agreement and schedule an in-depth exploratory discussion to evaluate the Client’s current situation and investment goals and objectives.
• Sparta Wealth Partners will provide a personal risk analysis to determine an appropriate investment strategy. This would include a review of any current investment portfolio and current risk tolerance.
• A financial plan will be created, provided and reviewed with the client.
• On-going services will be implemented at this point. The fees for on-going services are detailed in the section below, Item 5 – Fees and Compensation. Service Levels Sparta Wealth Partners’ retainer services are offered under ESSENTIAL, PREMIER and SIGNATURE Wealth Planning service levels. The ESSENTIAL level of service objectives are to initiate a savings and investment strategy, insurance needs, provide debt and student loan management, and financial goals counseling. The PREMIER level of service objectives are to provide a basic financial plan, focusing on investment strategy, education planning, and organization of the client’s financial life. The SIGNATURE level of service objectives are to provide a comprehensive financial plan, in-depth analysis and recommendations, and advise the client on any financial matters that may arise. Held Away Account Asset Management We use a third-party platform (Pontera) 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 login 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 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. Securities Based Line of Credit (SBLOC) As an ancillary service, Sparta Wealth Partners, offers certain clients with at least $100,000 in nonretirement assets, the opportunity to establish a line of credit which is backed by securities in their portfolio. The Company does not receive direct or indirect compensation for these Securities Based Lines of Credit (SBLOC) but offers this as a means of low cost of capital finance for these affluent clients. There are certain restrictions on what the funds can be used for (e.g., cannot be used to repay a margin loan, variable insurance products or any insurance product issued or brokered through an affiliate of the lender). The interest rate charged for the SBLOCs is on a tiered schedule where the rate drops as the credit limit rises. An additional discount is granted for clients with at least $5,000,000 in assets under management at the time of inception. In supervising this program, and in keeping with our fiduciary responsibility to our clients, the Company will disclose all relevant details to any client that shows interest in obtaining an SBLOC. Some of the possible risks from using an SBLOC include:
• unintended tax consequences;
• possible need for the client to sell certain holdings which in turn can negatively impact long-term investment goals;
• market conditions can magnify any potential for loss if the market turns against the client, they may be required to quickly deposit additional securities and/or cash in the account(s) or pay down the loan to avoid liquidation.
• The securities in the pledged account(s) may be sold to meet the collateral call, and the firm may sell the client’s securities without contacting them.
• A client may not be entitled to choose which securities or other assets in his or her account are liquidated or sold to meet a collateral call.
• In many cases, the firm may increase its maintenance requirements at any time and is not required to provide a client advance written notice.
• A client may not be entitled

to an extension of time on a collateral call. Increased market interest rates could also affect the applicable rate index that applies to your line of credit, causing the cost of the credit line to increase significantly. The Company actively addresses the risks above by educating the relevant client base on these factors and monitoring SBLOC balances, which are typically paid down in short order and routinely retired. Services Limited to Specific Types of Investments Sparta Wealth Partners generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs. Sparta Wealth Partners may use other securities as well to help diversify a portfolio when applicable. Sparta Wealth Partners offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client’s Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Sparta Wealth Partners from properly servicing the client account, or if the restrictions would require Sparta Wealth Partners to deviate from its standard suite of services, Sparta Wealth Partners reserves the right to end the relationship. C. Client Tailored Services and Client Imposed Restrictions A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Sparta Wealth Partners does not participate in any wrap fee programs. Sparta Wealth Partners has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $219,470,000 $0 March 29, D. Wrap Fee Programs E. Assets Under Management Portfolio Management Fees Sparta Wealth Partners’ advisory fees are negotiable, and do not exceed 2.00%. Fees are charged monthly in advance or arrears. The final fee schedule will be memorialized in the client’s advisory agreement and custodial agreements. Sparta Wealth Partners uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Consulting services are included in these fees for asset management services with the exception of unique circumstances that may require a separate agreement for financial planning services (description and fees are discussed below). If the situation warrants separate financial planning fees, it will be discussed upfront and a separate agreement will be negotiated. Clients may terminate the agreement without penalty for a full refund of Sparta Wealth Partners' fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. Clients who terminate investment advisory services during a month, are charged a prorated advisory free based on the date of Sparta Wealth Partners’ receipt of client’s written notice to terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and unearned fees will be immediately refunded. Long/Short Strategy For clients that elect a Long/Short strategy with a sub-advisor, a 1.00% annual asset-based and a 10% performance-based “incentive” fee will be charged. The annual asset-based fee is payable monthly in advance or in arrears, in accordance with the client’s agreement, and is based on the value of the client’s account at the end of the prior month, with performance-based fee being assessed quarterly in arrears. If management begins after the start of a month, fees will be prorated accordingly. With client authorization, fees are normally debited directly from client accounts. Held Away participant 401K accounts may be charged a lower fee depending on the scope and complexity of the plan options. Performance Fee Calculation Methodology Sparta Wealth Partners gives certain clients the option of being charged performance-based fees. Due to strict regulatory requirements, performance-based fees can only be charged to “qualified clients”. A qualified client is defined as a client that has over $1.1 million invested with us, OR a net worth of at least $2.2 million, excluding primary residence. Performance-based fees may not be charged to any client that does not meet the definition of a qualified client. For accounts that are charged performance-based fees, the performance-based fee component of the investment management fee is calculated as of December 31 of each year. When “Net Profits” are earned for the current period, Sparta Wealth Partners and the sub-advisor will internally share the performance fee of 10% of the Net Profits generated, subject to a “High Water Mark.” No