CAVU Wealth Management, Inc. is an independent registered investment adviser founded in January 2019 with its principal place of business located in California. The following individuals are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company):
• Michael S. Wynns, CEO
• Dan Gomes, CFO
• Phillip Jones, CCO, and Secretary TYPES OF SERVICES CAVU Wealth Management offers the following advisory services to our clients. Investment Supervisory Services ("ISS") Individual Portfolio Management Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we create and manage a portfolio based on that policy. During our data-gathering process, we collect suitability information including the client’s (1) age (or date of birth); (2) annual income; (3) total net worth (excluding primary residence); (4) liquid net worth; (5) employment status (if retired, former profession, if self- employed, type of business); (6) fair market value of primary residence (and outstanding debt); (7) tax status, which includes, type of account (natural person, entity, IRA, etc.), tax bracket, or tax strategy for the account(s); (8) investment objectives (defined to ensure client understanding); (9) investment experience (time/investment products); (10) investment time horizon; (11) liquidity (cash flow) needs; (12) risk tolerance; (13) other investments (types of investments held elsewhere); and (14) any other information related to the recommendations or investment advice (i.e., source of funds). As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis (please refer to Item 16). Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. We strive to meet with clients on an annual basis to remain current with a client’s objectives and goals. We will document and update any changes in a client’s suitability information as part of these annual reviews. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States government securities
• Options contracts on securities (please refer to refer Item 8. Investment Strategies: Option Writing) Please note that billing based on assets under management (AUM) is limited to the investment adviser version of the products listed above. Unmanaged or static assets are not included in AUM when calculating our management fee (i.e., Unmanaged variable products and limited partnership investment products). Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Institutional Intelligent Portfolios™ In addition to the above, CAVU Wealth Management offers an automated investment program (the “Program”) through which clients are invested in a range of investment strategies CAVU Wealth Management has constructed and manages, each consisting of a portfolio of exchange-traded funds (“Funds”) and a cash allocation. The client may instruct CAVU Wealth Management to exclude up to three Funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). CAVU Wealth Management uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisers and an affiliate of CS&Co., to operate the Program. CAVU Wealth Management is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). CAVU Wealth Management, and not Schwab, is the client’s investment adviser and primary point of contact with respect to the Program. CAVU Wealth Management is solely responsible, and Schwab is not 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. CAVU Wealth Management has contracted with SPT to provide our firm with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables CAVU Wealth Management to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). Based on information the client provides to us, CAVU Wealth Management will recommend a portfolio via the System. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but CAVU Wealth Management then makes the final decision and selects a portfolio based on all the information CAVU Wealth Management has about the client. The System also includes an automated investment engine through which CAVU Wealth Management manages the client’s portfolio on an ongoing basis through automatic rebalancing. Rebalancing: The System will rebalance a client’s account periodically by generating instructions to CS&Co to buy and sell shares of ETFs and depositing or withdrawing funds through the “Sweep Program,” considering the asset allocation for the client’s investment strategy. Rebalancing trade instructions can be generated by the System when (i) the percentage allocation of an ETF varies by a set parameter established by CAVU Wealth Management, (ii) CAVU Wealth Management decides to change the ETFs or their percentage allocations for an investment strategy or (iii) CAVU Wealth Management decides to change a client’s investment strategy, which could occur, for example, when a client makes changes to their investment profile or imposes or modifies restrictions on the management of their account. Accounts below $5,000 may deviate farther than the set parameters as well as the target allocation of the selected investment profile. Rebalancing below $5,000 may impact the ability to maintain positions in selected asset classes due to the inability to buy or sell at least one share of an ETF. For example, withdrawal requests may require entire asset classes to be liquidated to generate and disburse the requested cash. Sweep Program: Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a minimum of 4% of an account’s value to be held in cash and may be higher, depending on the investment strategy chosen for a client. The Cash Allocation will be accomplished through enrollment in the Sweep Program, a program sponsored by CS&Co. By enrolling in the Program, clients consent to having the free credit balances in their brokerage accounts at CS&Co swept into deposit accounts (“Deposit Accounts”) at Charles Schwab Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an FDIC-insured depository institution that is a Schwab affiliate. The Sweep Program is a required feature of the Program. If the Deposit Account balances exceed the Cash Allocation for a client’s investment strategy, the excess over the rebalancing parameter will be used to purchase securities as part of rebalancing. If clients request cash withdrawals from their accounts, this likely will require the sale of ETF positions in their accounts to bring their Cash Allocation in line with the target allocation for their chosen investment strategy. If those clients have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In accordance with an agreement with CS&Co, Schwab Bank has agreed to pay an interest rate to depositors participating in the Sweep Program that will be determined by reference to an index. CAVU Wealth Management charges clients a fee for our services as described below under Item 5 Fees and Compensation. CAVU Wealth Management’s fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that CAVU Wealth Management selects to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. CAVU Wealth Management does not pay SPT fees for the Platform so long as CAVU Wealth Management maintains $100 million in client assets in accounts at CS&Co. that are not enrolled in the Program. If CAVU Wealth Management does not meet this condition, then CAVU Wealth Management pays SPT an annual licensing fee of 0.10% (10 basis points) on the value of our clients’ assets in the Program. This fee arrangement gives CAVU Wealth Management an incentive to recommend or require that our clients with accounts not enrolled in the

Program be maintained with CS&Co. Financial Planning We provide financial planning services that may be broad-based, more narrowly focused or on a consultation basis, depending on the client’s needs and wishes.
• Broad-Based Financial Planning: CAVU Wealth Management will collect the pertinent data, conduct personal interviews with the client, and present a broad-based written financial plan to the client.
• Specific Financial Planning: CAVU Wealth Management will collect the pertinent data, conduct personal interviews with the client, and present selected report(s) to the client that addresses one or more of the areas discussed below.
• Hourly Financial Consultation: CAVU Wealth Management will provide financial consulting services on an hourly basis. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information, and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current, and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning, and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney and asset protection plans. We gather the required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written financial plan. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. The implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. Retirement Plan Services CAVU Wealth Management provides advisory services to retirement plans (i.e., 401(k) plans). In this capacity, CAVU Wealth Management provides both fiduciary services as well as non-fiduciary services. Fiduciary services include, but are not limited to:
• Provide non-discretionary investment advice to the client about investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. The client shall have the final decision-making authority regarding the initial selection, retention, and removal of investment options at the Plan level. After the investment menu is established, the participant elects their allocation in the retirement plan and the Record Keeper/Custodian executes trades for plans based on the Client’s payroll submission.
• Assist in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan and shall set forth the asset classes and investment categories to be offered under the Plan, as well as the criteria and standards for selecting and monitoring the investments. The client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt the investment policy statement.
• Prepare periodic investment advisory reports that document consistency of fund management and performance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options.
• Meet with the client on a periodic basis to discuss reports and recommendations.
• Provide investment advice to the client with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who fail to make an investment election. Non-fiduciary services include, but are not limited to:
• Assist in the education of the participants in the Plan about general investing principles and the investment alternatives available under the Plan in accordance with Department of Labor requirements. The adviser will not provide investment advice concerning the appropriateness of any investment option for a particular participant or beneficiary under the Plan and will not be acting as an ERISA fiduciary for purposes of providing educational services.
• Assist in the group enrollment meetings designed to increase retirement plan participation among employees. The adviser will not be acting as an ERISA fiduciary for purposes of providing enrollment support services. Note: CAVU Wealth Management has no responsibility to provide any services related to the following types of assets: employer securities, real estate (except for real estate funds and publicly traded REITs), stock brokerage accounts or mutual fund windows, participant loans, non-publicly traded partnership interests, other non-publicly traded securities (other than collective trusts and similar vehicles), or other hard-to-value securities or assets. Such assets (except for real estate funds, publicly traded REITs, and collective trusts and similar vehicles) are referred to collectively as “Excluded Assets.” The Excluded Assets will be disregarded in determining the fees payable to CAVU Wealth Management pursuant to Item 5 of this Brochure, and the fees will be calculated only on the remaining assets (the “Included Assets”). Participant Account Management (Discretionary) We provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, Health Savings Accounts (HSA), and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other investment accounts, though using different tools as necessary. 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 interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS CAVU Wealth Management will tailor its advisory services to its client’s individual needs based on meetings and conversations with the client. If clients wish to impose certain restrictions on investing in certain securities or types of securities, we will address those restrictions with the client to have a clear understanding of the client’s requirements. WRITTEN AGREEMENTS Prior to engaging CAVU Wealth Management to provide advisory or financial planning services, clients are required to enter into a written agreement with CAVU Wealth Management setting forth the terms and conditions under which we render our services. Termination of Agreement A client agreement may be canceled via written correspondence, phone, or email at any time, by either party, for any reason upon receipt of 30-day notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. We will provide a final invoice that includes the fees charged, the formula used to calculate the fees, the fee calculation itself, the time period covered by the fees, and if applicable, the amount of assets under management the fee was originally based upon. If a client terminates its relationship with CAVU Wealth Management before we finish the client’s written financial plan or analysis, we will deliver the completed portions of any documents to the client. Assignment of Agreements Agreements may not be assigned without the client’s written consent. WRAP FEE PROGRAMS CAVU Wealth Management does not sponsor or provide investment management services to a wrap program. AMOUNT OF MANAGED ASSETS As of December 2023, our firm is currently managing approximately $ 114,497,809.00 of clients' assets ($ 110,963,273.00 on a discretionary basis and $ 3,534,536.00 on a non-discretionary basis).