Phoenix Wealth Advisors, Inc. (“Phoenix” or “Adviser”), owned by Georgios Livanos and Mark Rhoades, has been an investment adviser registered with the Securities and Exchange Commission since 2001. Phoenix focuses on providing sophisticated financial planning and wealth management services to the exceptional people who make up this community. From business executives and entrepreneurs to scientists and educators, we work with a broad range of clients and meet a wide variety of needs. Drawing on more than a century of financial education and industry experience, our team will work with you to define your financial goals, establish the degree of risk you are comfortable with and tailor a wealth strategy designed to achieve lasting well-being. Advice is tailored to the individual client’s needs through interviews with clients, the collection of important information, and detailed financial planning, as applicable. Clients may be able to impose reasonable restrictions on their accounts. Reasonable restrictions may include the designation of particular securities or types of securities that should not be purchased in their account (i.e., Company XYZ or companies involved in a particular industry, etc.), or should be sold if held in their account. However, in some cases where investment discretion has been delegated to a third-party manager, that manager may determine that the implementation of such a restriction may be impractical. In the event that happens, the client will be notified promptly. As of December 31, 2023, Phoenix had the following in assets under management: Discretionary Accounts: 1,425 Assets: $ 474,044,173 Non-Discretionary Accounts: 9 Assets: $ 14,318,092 Total Accounts: 1,434 Assets: $ 488,362,265 Financial Planning Services Phoenix offers a range of financial planning advisory services to its clients. Such services may include a review of all aspects of an individual’s current financial situation, with emphasis on:
• Income tax planning,
• Estate tax planning,
• Insurance planning,
• Investment planning,
• Retirement planning, and
• Capital needs planning. To the extent other services are needed, the Adviser will assist the individual in those areas in which it is competent to give advice. The process generally begins with an introductory meeting with the Investment Advisory Representative (“IAR”) to discuss the scope of the plan and principal financial objectives of the client. At the client’s request and after a contract has been completed, the IAR would then receive from the client all necessary financial information. Additional information may be requested before the presentation of the plan. During these initial meetings, the IAR will ask the client about his/her risk background and past investment experience. The written financial plan will present the client’s financial strengths and weaknesses. General areas reviewed may include tax and cash flow planning, retirement planning, debt reduction strategies, educational funding requirements, estate analysis, and alternative investment patterns for either increased return or risk adjustment dependent on the client’s age, assets, and current earned income. Phoenix uses Goal Planning and Monitoring software to create its financial plans. In addition, the IAR may be asked to furnish analysis for closely held small business owners. The plan should enable the client to determine financial goals and objectives, both long- and short-term. As a follow-up service, Phoenix will, at the client’s request, assist the client in implementing the recommendations, including referral to other practicing professionals (such as attorneys and accountants) whose services may be required. The client may utilize Phoenix for a single consultation or on a continuous basis at periodic intervals. The client is under no obligation to implement the plan through Phoenix. Either the client or Phoenix may terminate the engagement at any time with written notice. The plan is the basic instrument for Phoenix to know the client and serves as a guideline for offering investment supervisory services. Retirement Plan Services In addition to providing individual financial planning and investment advisory consulting services to individuals and corporations, we may also provide advice and consultation to retirement plan sponsors and pension plans. Services rendered may include, but are not necessarily limited to, the development of a documented investment process, asset allocation, research and investment recommendations, plan participant education, investment or investment manager performance monitoring, and guidance to the plan sponsors on its fiduciary obligations to plan participants. In providing these services, we may act as a fiduciary as defined under Section 3(21)(A)(ii) of ERISA but will serve in such capacity only with respect to the provision of ERISA-defined investment advice. Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. Phoenix will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, Phoenix will be considered a fiduciary under ERISA. For example, Phoenix will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to

the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. TYPES OF ADVISORY SERVICES Your IAR works with you to determine the appropriate investment objectives based on the information you provide initially, and periodically thereafter. With this information, you and your IAR may select one of the following programs. If you wish to impose or modify an existing investment restriction, you may do so at any time by discussing this with your IAR. Phoenix and its IARs offer various types of advisory services. These advisory services include asset management, investment advice, and individual investment advisory consulting services, retirement plan consulting services and financial planning. Your IAR may act as an investment manager within certain investment programs or may recommend other affiliated or non-affiliated asset managers. For more information regarding methods of analysis, investment strategies, and risk of loss, please reference Item 8 Methods of Analysis, Investment Strategies and Risk of Loss later in this brochure. We provide investment advisory services through the following programs: Accounts Managed by Your IAR Ambassador The Ambassador program is a wrap fee investment advisory account offered by Phoenix and administered by Raymond James & Associates, Inc. (“RJA”), a member of the NYSE/SIPC, in which you are provided with ongoing investment advice and monitoring of securities holdings. Your IAR will manage your account on a discretionary or non-discretionary basis according to your objective. Ambassador offers you the ability to pay an asset-based advisory fee which includes transaction costs within the advisory fee in lieu of a commission for each investment transaction within the account. Phoenix receives a portion of the fee. Dividend Strategy Within the Ambassador Program, we offer an equity income Dividend Strategy Portfolio that integrates the strategy a of third-party money manager with our own input with regard to individual security concentration levels or additional holdings. In this strategy, we will identify a third-party manager whose strategy we believe in, and we will mirror most of their trades. However, we will use our own research to enhance the strategy’s trades and holdings when we feel it is advantageous to the overall goal of the strategy. Changes to the third-party manager’s strategy can include concentration levels, different securities in the same industry, or an eliminate of securities in a particular industry, as we deem in the best interest of our clients, but in line with the overall strategy. Multi-Cap Growth Strategy We also offer a Multi-Cap Growth Strategy that integrates the holdings from an exchange-traded fund (ETF) with a similar strategy with our own input with regard to individual security holdings and mutual funds we believe will enhance the strategy. In this strategy we use approximately 30% of the securities from the ETF that is in-line with our own research and combine them with mutual funds of our choosing to create a portfolio for this strategy. Similar to our Dividend Strategy, while we will use the holdings of a publicly traded ETF as our core holdings, we will manage concentrate levels and use other mutual funds or individual securities as we deem appropriate. Other Advisory Services The IAR offers a full range of advisory services not directly related to investments. These services include individual financial planning (discussed above), pension plan design and consultation, pension plan participant advisory services, small business financial planning, and seminars for investors. Phoenix’s written financial plan could include advice on family educational needs, insurance needs, and/or retirement planning. This information would outline the scope of the issue as well as financial techniques that could be implemented to fund the need. Phoenix offers pension planning and plan implementation services to small and medium-sized businesses. Service will address the need of a company to install a comprehensive retirement plan, provide an overview of the various plan design characteristics, and implement the selection of an attorney to draft the pension trust document and the selection of a third-party administrator. As mentioned above, Phoenix may provide 3(21) fiduciary services for retirement plans for which is it compensated by the Plan Sponsor. Important Note to Retirement Investors: When we (the firm and your financial professional) 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 of 1974, as amended (“ERISA”) and/or the Internal Revenue Code, as amended (“IRC”), 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. We have a conflict of interest with you when we recommend a rollover / transfer of retirement assets and receive more compensation as a result. We mitigate this conflict of interest by providing you with relevant information, reviewing that information with you, answering your questions, and recommending only alternatives that we believe are in your best interest. We have provided you with other required disclosures, along with your account terms and conditions and/or advisory agreement that describe the specific services we will perform and/or terms and conditions of our relationship with you. This is important information so please read it carefully. If we provide you, as a plan participant, with individualized investment advice for your ERISA or non-ERISA plan assets, such as 401(k)s and 403(b)s, our advice is limited to the investment options approved by the plan. Because of this, our advisory services are limited to those available investment options and your retirement account will be reviewed by us at least quarterly and, when deemed necessary, your financial professional will advise on allocation changes or rebalancing strategies.