Signet is an investment adviser registered with the SEC? and is a limited liability company (LLC) formed under the laws of the State of Delaware. Jonathan B Spencer is the Chief Executive Officer (CEO), Member and Owner of Signet. Signet is owned by Signet Investment Group LLC, which is in turn owned by Jonathan B Spencer, Blue Lake Capital LLC (100% owned by David Ventura), Liccar Consulting LLC (100% owned by Michael Liccar) and Andiamo Vento LLC (100% owned by Thomas J. Laughlin). Full details of the education and business background of Jonathan B Spencer are provided at Item 19 of this Disclosure Brochure. Signet filed its initial application to become registered as an investment adviser in October 2017. Introduction The investment advisory services of Signet are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of Signet (referred to as your investment adviser representative throughout this brochure). Your investment adviser representative typically is not an employee of Signet; rather, your investment adviser representative typically is a principal or an independent contractor of Signet. Your investment adviser representative is limited to providing the services and charging investment advisory fees in accordance with the descriptions detailed in this brochure. Description of Advisory Services The following are descriptions of the primary advisory services of Signet. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and Signet before we can provide you the services described below. Portfolio Management Services – Signet offers asset management services, which involves Signet 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. 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 of the Account. 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. Signet Private Wealth LLC Page 5 Form ADV Part 2A Disclosure Brochure It is important that you understand that we manage investments for other clients and may give them advice or take actions 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. Conflicts may 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. When recommending that a client rollover his or her account from current retirement plan to an IRA, Signet and its investment adviser representatives have a conflict of interest. Signet and its representatives can earn investment advisory fees by recommending that a client rollover his or her account at the retirement plan to an IRA; however, Signet and its investment adviser representatives will not earn any investment advisory fee if client does not rollover the funds in the retirement plan (unless a client retained Signet to provide advice about the client’s retirement plan account). Thus, Signet and its investment adviser representatives have an economic incentive to recommend a rollover of the retirement plan account, which is a conflict of interest and the objectivity of the advice rendered to Client is biased. Signet has taken steps to manage this conflict of interest arising from rolling over funds from an ERISA covered retirement plan to an IRA and has adopted written policies and procedures whereby Signet and its investment adviser representatives will disclose the advantages/disadvantages of the retirement plan/IRA rollover options available to the client and will only recommend rollover if in the best interest of the client. Financial Planning Services - Signet offers financial planning services, which involve preparing a written financial plan covering a specific topic or multiple topics. Financial planning will in some cases be incidental to asset management services by virtue of the features on our client portal. Full Written Financial Plan We provide full written financial plans, which typically address the following topics: Investment Planning, Retirement Planning, Education Planning, Asset Allocation, Budgeting, Cash Flow Analysis, Estate Planning, Risk Management, and Alternative Investments. For an engagement to complete a full written plan, the financial advisor will typically complete six steps: 1. Initial fact-finding meeting. 2. Follow-up phone call, if necessary, to clarify or verify information. 3. Analyze the client situation through the appropriate software tool. 4. Create the full written financial plan. 5. Deliver the recommendation at a client meeting. 6. Provide up to 30 days for client follow-up. When providing financial planning services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. Signet Private Wealth LLC Page 6 Form ADV Part 2A Disclosure Brochure Modular Written Financial Plan We also provide modular written financial plans which only cover those specific areas of concern mutually agreed upon by you and us. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. You should be aware that there are important issues that may not be taken into consideration when your investment adviser representative develops his or her analysis and recommendations under a modular written financial plan. Written financial plans prepared by us do not include specific recommendations of individual securities. For an engagement to complete a modular written plan, the financial advisor will typically complete six steps: 1. Initial fact-finding meeting. 2. Follow-up phone call, if necessary, to clarify or verify information. 3. Analyze the client situation through the appropriate software tool. 4. Create the modular written financial plan. 5. Deliver the recommendation at a client meeting. 6. Provide up to 30 days for client follow-up. The hours estimated to complete a modular plan depends on the nature of the engagement and may cover the following areas:
• Investment Planning;
• Retirement Planning;
• Education Planning;

• Asset Allocation;
• Budgeting;
• Cash Flow Analysis;
• Estate Planning;
• Risk Management; and
• Alternative Investment Analysis/Planning. We will provide you with an estimate in writing which is specific to your situation prior to starting the modular plan. High Net Worth Clients For high-net-worth clients, Signet may provide the following services which are outside the scope of a full or modular financial plan as described above. These services include family meeting preparation & facilitation, philanthropic planning, portfolio risk evaluation, data aggregation services, transaction consulting, and other ad hoc services. The hours depend on the nature of the engagement. Signet will charge an hourly fee for these services ranging from $100/hr. to $500/hr. depending on the nature of the work and the individuals involved in providing the service. In all instances, and engagement letter defining the scope of the project, the individuals involved, the rate per hour, and the estimated hours required. Signet will not charge more than the total amount agreed to by the client in the engagement letter, unless client expressly agrees to the expanded scope in writing. Signet Private Wealth LLC Page 7 Form ADV Part 2A Disclosure Brochure Signet may use a third-party registered investment adviser as sub-adviser to assist with financial planning services provided to high net worth clients. In such cases, the sub-adviser will charge you a separate fee in addition to the fee charged by Signet. You will sign a separate engagement with the sub-adviser. A complete description of the sub-adviser’s services and fees will be disclosed in the sub-adviser’s Form ADV Part 2A that will be provided to client. Our financial planning services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning and consulting recommendations. To the extent that you would like to implement any of our investment recommendations through Signet or retain Signet to actively monitor and manage your investments, you must execute a separate written agreement with Signet for our asset management services. Signet may recommend client utilize specific sub-adviser(s) (individually “Sub-Adviser” and collectively Sub-Advisers) to assist Signet in providing the above financial planning or consulting services. A complete description of the Sub-Adviser’s services and fees will be disclosed in the Sub-Adviser’s Form ADV Part 2A that will be provided to client. Health Savings Account Program Custodial Account - Signet has signed an agreement with a custodian to offer Health Savings Account (“HSA”) Program Custodial Accounts. The Custodial Account is established to provide a method for a “Participating Employer” to offer an HSA option to its employees, enabling Electing Employees to invest their individual HSAs in a selection of mutual funds and other appropriate investment products (“Funds”). Signet can also offer HSA Program Accounts to individuals directly. Signet designates the Funds (“Fund Lineup”) that will be available in the Custodial Account for selection by the Electing Employees or individuals. Signet will periodically monitor and, as appropriate, remove and replace, Funds in the Fund Lineup. The monitoring analysis will include such information as shall be appropriate for determining whether the Fund Lineup continues to be prudent, including performance assessment and fee benchmarking as well as adherence to such investment policy as Signet shall have established for the Funds. Newsletters Signet occasionally prepares general, educational and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific individual. Seminars Signet may occasionally provide seminars in areas such as financial planning. Seminars are always offered on an impersonal basis and do not focus on the individual needs of participants. Workshops Signet offers educational, informative and motivational workshops to the public as well as to associations, family foundations and employers. Workshops are always offered on an impersonal basis and do not focus on the individual needs of the participants. Limits Advice to Certain Types of Investments Signet primarily provides investment advice on the following types of investments: Signet Private Wealth LLC Page 8 Form ADV Part 2A Disclosure Brochure
• Mutual Funds
• Exchange Traded Funds (ETFs)
• Exchange-listed Securities
• Fixed Income Securities (e.g. bonds)
• Alternative Investments Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Signet’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 and consulting services are always provided based on your individual needs. When providing financial planning and consulting 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 may 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. 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); Signet Private Wealth LLC Page 9 Form ADV Part 2A Disclosure Brochure
• 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. Client Assets Managed by Signet As of December 2023, Signet had a total of $127,826,149 in assets under management on a discretionary basis and $15,856,605 in assets under management on a non-discretionary basis.