Item 5 – Additional Compensation ............................................................................................................................................ 21 Item 6 – Supervision ................................................................................................................................................................. 22 Form ADV Part 2B – Brochure Supplement ............................................................................................................. 23 Item 2 – Educational Background and Business Experience .................................................................................................... 24 Item 3 – Disciplinary Information ............................................................................................................................................... 24 Item 5 – Additional Compensation ............................................................................................................................................ 24 Item 6 – Supervision ................................................................................................................................................................. 24 Form ADV Part 2B – Brochure Supplement ............................................................................................................. 25 Item 2 – Educational Background and Business Experience .................................................................................................... 26 Item 3 – Disciplinary Information ............................................................................................................................................... 27 Item 5 – Additional Compensation ............................................................................................................................................ 27 Item 6 – Supervision ................................................................................................................................................................. 27 Form ADV Part 2B – Brochure Supplement ............................................................................................................. 28 Item 2 – Educational Background and Business Experience .................................................................................................... 29 Item 3 – Disciplinary Information ............................................................................................................................................... 29 Item 5 – Additional Compensation ............................................................................................................................................ 29 Item 6 – Supervision ................................................................................................................................................................. 29 Form ADV Part 2B – Brochure Supplement ............................................................................................................. 30 Item 2 – Educational Background and Business Experience .................................................................................................... 31 Item 3 – Disciplinary Information ............................................................................................................................................... 31 Item 5 – Additional Compensation ............................................................................................................................................ 32 Item 6 – Supervision ................................................................................................................................................................. 32 Privacy Policy............................................................................................................................................................................ 33 Page 4 A. Firm Information Prien Asset Management, LLC d/b/a WaterRock Wealth Management (“Prien Asset Management” or the “Advisor”) is a registered investment advisor located in the State of New Mexico. The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of New Mexico. Prien Asset Management was founded in April 2018 and is owned and operated by Christopher Prien (Managing Director and Wealth Advisor). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Prien Asset Management. B. Advisory Services Offered Prien Asset Management offers investment advisory services to individuals and high net worth individuals (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Prien Asset Management’s fiduciary commitment is further described in the Code of Ethics. For more information regarding the Advisor’s Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Prien Asset Management provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Prien Asset Management works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Prien Asset Management will implement the investment strategy with its internal management and/or the use of unaffiliated money managers or investment platforms (as described below). Internal Investment Management - Prien Asset Management customizes its investment management services for its Clients. Prien Asset Management will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Prien Asset Management’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Prien Asset Management will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Prien Asset Management evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Prien Asset Management may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Prien Asset Management may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing

cash positions as a possible hedge against market movement. Prien Asset Management may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 5 At no time will Prien Asset Management accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement. Please see Item 12 – Brokerage Practices. Use of Independent Managers – Prien Asset Management may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Schwab Institutional Intelligent Portfolios – The Advisor may recommend an automated investment program through which Clients are invested in a range of investment strategies Prien Asset Management has constructed and manages (“Program”). The Client’s portfolio is held in a brokerage account opened by the Client at Charles Schwab & Co., Inc. (“Schwab”). The Advisor utilizes the Institutional Intelligent Portfolios® platform, offered by Schwab Performance Technologies, a software provider to independent investment advisors and an affiliate of Schwab, to operate the Program. The Advisor remains the Client’s investment advisor and primary point of contact. The Advisor is responsible for determining the appropriateness of the Program for the Client, choosing a suitable investment strategy and portfolio for the Client’s investment needs and goals, and managing that portfolio on an ongoing basis. Orion Portfolio Solutions, LLC - Prien Asset Management has entered into an agreement with Orion Portfolio Solutions, LLC formerly known as FTJ FundChoice, a subsidiary of Orion Advisor Solutions, Inc. (“Orion”). Prien Asset Management may recommend that a client utilize the services of Orion. Morningstar Managed Portolios;- Prien Asset Management has entered into an agreement with Morningstar Managed Portolios. Prien Asset Management may recommend that a client utilize the services of Morningstar. Sub-Advisory Services A sub-advisory relationship is defined as one in which another firm hires an outside firm to provide investment advisory services for their clients. We have been retained to serve as sub-adviser to clients of unaffiliated registered investment advisers. Clients should understand that the unaffiliated registered investment adviser is responsible for analyzing the financial needs of its clients and for also determining the suitability of our services for their client. Clients should understand that when we have been retained to serve as sub-adviser, Prien Asset Management relies solely on the unaffiliated registered investment adviser to make such determination, as we are generally not provided sufficient information by the investment adviser to perform an assessment of client suitability. Absent specific client guidelines, directed brokerage arrangements, and cash flows, we will manage these accounts similarly to other separately managed client accounts within the same strategy based on the strategy’s characteristics and the availability of cash in the individual accounts. In these sub-advisory relationships. Prien Asset Management enters into a sub-advisory agreement with the unaffiliated registered investment adviser to provide portfolio management services to the adviser’s clients. As part of our sub-advisory agreements with such investment advisers, we do not pay them a fee for referring clients to us. We receive an agreed upon percentage of the fees, which is .65%, charged by the investment adviser for the sub-advisory services. The fee is calculated using average daily balance collected monthly in arrears. Prien Asset Management will deduct their fee directly from the client’s account. The sub-advisory agreement between us and the investment adviser through Schwab states the manner and amount that we will be paid and also describes the services we will provide to the investment adviser’s clients. Clients of these investment advisers compensate their investment adviser directly and the investment adviser in turn pays us a fee as specified in our subadvisory agreement with the investment adviser. Page 5 Financial Planning Services Prien Asset Management will typically provide a variety of financial planning and consulting services to Clients, either as a component of investment management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Prien Asset Management may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Page 6 Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Basic Estate Planning Services Prien Asset Management offers Estate Planning services to assist clients with general information as it applies to reviews of existing plans, gathering information needed to provide outside firms in the creation of documents, and updating existing plans for clients. Depending on the client needs and desires for estate planning document review, preparation, or updates Prien Asset Management will engage with an unaffiliated company, EncoreEstate Plans, Inc. which is a third-party scrivener service or with estate planning attorneys to coordinate basic estate plans. Basic estate plans can include the following:
• Trust
• Certification of trust
• General transfer
• Property agreement for community property states
• Financial Power of Attorney
• Medical Power of Attorney or Advanced Health Care Directive
• HIPPA Release
• Will
• Deed(s) for real property C. Client Account Management Prior to engaging Prien Asset Management to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Prien Asset Management, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Prien Asset Management will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Prien Asset Management will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Prien Asset Management will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Prien Asset Management does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2023, Prien Asset Management manages $ 113,231,308 .00 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Page 8