Wellspring Wealth Management LLC (“Wellspring Wealth”), formerly known as InvestLinc Wealth Management Group LLC, was founded in 2005. We are an investment advisor registered with the Securities and Exchange Commission as required by the Investment Advisers Act of 1940. We have offices located in Alpharetta and Atlanta, Georgia and Bluffton, South Carolina. We are wholly owned by Wellspring Wealth LLC. Wellspring Wealth is owned 24% by JBSGBJ Holdings LLC, 5% by Mark Winston, 20% by Dennis R. Wright, and 51% by J. David Glover. JBSGBJ Holdings LLC has six individual members. Greg A. Raabe is the manager and the only member with more than 25% ownership. We have a business continuity plan in place that provides for the loss of communications, office locations, services or key people. This brochure provides information about Wellspring Wealth and the following types of advisory services:
• Investment advisory services
• Third party program selection
• Portfolio advisement or monitoring services
• Financial planning services
• Retainer services
• Consulting services Wealth management services are made available to clients primarily through individuals associated with Wellspring Wealth as Investment Adviser Representatives (IARs). For more information about the IAR providing advisory services, you should refer to the Brochure Supplement for the IAR. The Brochure Supplement, or Form ADV Part 2B, has been added to the end of this document for ease in providing it to you. If you do not receive a Brochure Supplement with your IAR information, you should contact your IAR or Wellspring Wealth at [email protected]. Our IARs rely on the information obtained from you and your other professionals (attorney, accountant, real estate agent, insurance agent, private banker, trust officer, stockbroker, etc.). We do not verify information received from you or your professionals. You are responsible for notifying us when there is any change in your financial situation and/or objectives that would impact the recommendations or services we provide. As of December 31, 2023, our firm managed approximately $439,821,274 in assets for approximately 498 accounts. Investment Advisory Services You provide your investment goals and objectives to us to assist in managing your portfolio. We assist you in establishing the appropriate portfolio objective and suitable asset allocation. We offer investment advisory services to you through an individually tailored investment portfolio. Your portfolio may consist of one or more accounts. Your portfolio is managed by a designated IAR. You authorize us to purchase and sell open and closed-end mutual funds, exchange traded funds and notes (ETFs and ETNs), Real Estate Investment Trust (REIT) funds, stocks and bonds that have been reviewed by our Investment Policy Committee. You authorize account management on either a discretionary or non- discretionary basis. We do not custody assets. Accounts are held in your name at an independent custodian which may include LPL Financial and/or Schwab Advisor Services. Account statements are provided to you directly from your account custodian. We will provide periodic performance reports to you. The details of the account relationship are stated in your Advisory Agreement and the custodian’s account paperwork. We may assist you with retirement plan accounts and this assistance may present a conflict of interest. When you leave an employer there are typically four options regarding an existing retirement plan account and you may use a combination of these options; 1) if permitted, leave the funds in your former employer’s plan, 2) if roll overs are permitted and you have new employer with a plan available, roll over the funds to your new employer’s plan, 3) roll over to an Individual Retirement Account (“IRA”), or 4) withdraw or cash out your funds from the plan which may have adverse tax consequences depending on your age. When we recommend that you roll over your retirement plan assets into an account to be managed by us, such a recommendation creates a conflict (benefit to us) when we earn an advisory fee on your rolled over funds. You are under no obligation to roll over retirement plan assets to an account managed by us. Advisory services may be terminated by either party. Termination happens thirty days after receipt of a written notice by the other party. You may terminate the Advisory Agreement within five days of execution without penalty and receive a full refund of fees paid. Third Party Program Selection We offer asset management services to you through third party programs. By participating in these programs, you may authorize a third-party manager to purchase and sell mutual funds, equities, fixed income securities and other securities. Third party managers have discretionary authority over program accounts. You may place restrictions on their discretion. We will assist you in selecting third party investment programs. Discretionary authority to hire and fire third party managers and reallocation of your assets to other investments is assumed by us. In addition to evaluating and recommending programs to you, we will review reports provided to you by the third-party programs. Additionally, we will contact you periodically to review your financial situation and objectives, communicate information to the third-party program manager as warranted, and assist you in understanding and evaluating the services provided by the third-party program. Performance reports are provided to you by the third-party investment manager. Account relationship details are stated in the third-party investment advisor’s Form ADV and your program account agreement. Termination of a third-party program account is subject to the terms outlined in the program account agreement. LPL Financial Platforms – Strategic Wealth Management (SWM) We may provide advisory services through certain programs offered through LPL Financial LLC (LPL) platforms, a registered investment adviser and broker-dealer. Below is a brief description of each program recommended by us. LPL offers custodial accounts called Strategic Wealth Management (SWM) to support investment advisory services provided by us. Within these accounts, our IARs provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (ETFs), real estate investment trusts (REITs), equities, and fixed income securities. The advice is tailored to your individual needs based on your investment objectives and financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary according to your investment profile. More specific account information and acknowledgements are provided in the account opening documents. Prior to March 16, 2024, SWM was offered in two different programs, SWM I or SWM II. Since that date, SWM accounts have been consolidated into a single program. Under

the consolidated SWM program, SWM clients will pay transaction charges for the purchase and sale of certain securities in their accounts (old SWM I) unless the investment adviser elects to pay transaction changes on their behalf (old SWM II). . When Wellspring elects to wrap (or include) transaction fees as part of the advisory fee, it results in a wrap program. This is offered to you under our Wellspring SWM wrap fee program where our firm acts as the sponsor and portfolio manager. Please see Appendix 1 – Wrap Fee Brochure, which is included as a supplement to this Disclosure Brochure. The advisory fee for Wellspring SWM accounts may be higher in percentage terms than non-wrap SWM accounts due to account size and including transaction fees. Depending on various factors, such as anticipated trading levels, whether your account was part of an advisory business acquisition by us, your IAR will work with you to determine the appropriate account option. Model Wealth Portfolios Program (MWP) MWP is a wrap fee program where LPL serves as the sponsor and portfolio manager. While LPL serves as the wrap fee sponsor and portfolio manager, we manage the allocation of funds between different portfolios and available fund selections. MWP offers clients a professionally managed mutual fund asset allocation program. We will obtain the necessary financial data from you, assist you in determining the suitability of the MWP program and assist you in setting an appropriate investment objective. Your IAR will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with your investment objective. LPL’s Research Department or third-party portfolio strategist are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet which includes the account agreement and LPL Form ADV program brochure and the Form ADV, Part 2A of LPL or the applicable program. Portfolio Advisement Service We offer advisement service for your portfolios or investments held with other custodians. We do not have discretion nor execute the purchase or sale of investments. We will meet with you to determine an appropriate investment strategy that reflects your overall investment objectives and financial situation. We will then assist you in creating an appropriate asset allocation model and determine the various investment selections appropriate for your allocation. The number and type of investments recommended will be determined by you, the limitations of the accounts, and your financial objectives. We will monitor the investment allocation and meet with your periodically to review the appropriateness of the investments and allocations. Although we are not involved in the purchase or sale of these investments, we will supervise your portfolio and make recommendations to you as market factors or your needs dictate. Portfolio Monitoring Service We offer monitoring of your portfolios or investments held with other independent registered investment advisors. We are not involved in the purchase or sale of these investments. We will meet with you to review performance, asset allocation, tax issues, and changes in your objectives and/or situation. We will review various investments, including individual stocks and mutual funds, to determine their appropriateness given your financial objectives and situation. Your investments will be monitored quarterly, or as specified by you. Financial Planning Services We offer personal financial planning services. Financial plans are based upon your financial goals, objectives, assets, liabilities, income and tax status. You may select a financial plan that is broad-based or focused on a specific area. The Financial Planning Agreement specifies the planning items included. Available planning items include:
• Account Aggregation
• Asset Protection
• Business Continuity
• Charitable Planning
• Education Planning
• Estate Planning
• Executive Compensation Consulting
• Family Office Consulting
• Income Planning
• Insurance Planning
• Retirement Planning
• Trust Services Consulting
• Investment Policy Statement Creation IARs gather information through in-depth interviews and related meetings. Information gathered includes your current financial situation, planning activities, future goals and objectives. We assume that the information received from you or from other professionals is complete and accurate. You receive an analysis of your current situation and recommendations to address your goals and objectives. You may terminate the Financial Planning Agreement without penalty within five days of execution. After the five-day period, you may terminate the Financial Planning Agreement at any time and receive a refund of unearned fees, if any. The Financial Planning Agreement terminates when mutually agreed upon services have been completed to your satisfaction and the final invoice has been delivered. Retainer Services We offer retainer services through the Financial Planning Agreement. Retainers are for ongoing services which include assistance in implementation of planning recommendations, planning meetings, service reminders, reviews and updates. Retainer services may be terminated upon notice by either party. Financial planning recommendations are implemented at your discretion. You are under no obligation to implement recommendations. We recommend you work closely with your attorney, accountant, real estate agent, insurance agent, private banker, trust officer and/or stockbroker in implementing recommendations. At your request, IARs may recommend other professionals to assist you. Other professionals are engaged directly by you. IARs have established business relationships with other professionals that they may recommend to you. IARs will disclose existing relationships to you which, at times, may present a conflict of interest. We monitor potential conflicts of interest with our IARs and other professionals by maintaining reports on their receipt of referrals, gifts, and business entertainment. Consulting Services We offer consulting services consistent with your financial status, goals, and objectives. The consulting service may include providing advice regarding the planning items found under the Financial Planning Services above. You may request a written analysis or report from us as part of the consultation. You may terminate the Financial Planning Agreement for consulting without penalty within five days of execution. Termination after the five-day period will result in a refund of any unearned fees based upon the time invested and work already completed.