Formation and Firm History The firm filed its initial registration as an investment adviser with the US Securities & Exchange Commission (“SEC”) on May 15, 2006 as Werba & Davis Advisory Services, LLC. From January 1, 2007 until January 1, 2011 the firm was known as Werba & Davis Advisory Services, LLC until changing its name to Werba Rubin Wealth Management, LLC on January 1, 2011 upon the retirement of Barbara Davis from the firm. On June 15, 2017, Werba Rubin Wealth Management was renamed Werba Rubin Papier Wealth Management due to a merger between WRWM and Fluent Wealth. Ownership is now split evenly between Alan Werba, Aaron Rubin, and Jason Papier. Investment Services Most WRP investment advisory clients participate in one of four services sponsored by Buckingham Strategic Partners, LLC (“Buckingham”): (1) Structured Investing Asset Management, a portfolio allocation service utilizing primarily no-load, asset-class mutual funds advised by Dimensional Fund Advisors (“DFA”); (2) Structured Investing Portfolio Services, a portfolio allocation service utilizing primarily no- load, asset-class mutual funds advised by Buckingham and sub-advised by DFA (the SA Funds – Investment Trust or “SA Funds”); (3) Structured Investing Advantage, a service similar to Structured Investing Portfolio Services that allows additional stocks, bonds and funds be held in addition to the Buckingham and DFA offerings; and (4) 401(K) and Other Retirement Asset Management Services, a service offering risk-based portfolios utilizing primarily no-load, asset-class mutual funds managed by DFA. Under these four portfolio allocation services, Buckingham provides quarterly performance reports, quarterly fee billings, quarterly portfolio re-optimization analysis and annual supplemental tax reporting (when applicable) to WRP clients. Buckingham also performs daily downloads from custodians, account reconciliations with custodial account records and initiates trades in client accounts in its advisory capacity with the help of the account custodian. The custodians utilized by WRP clients include Charles Schwab & Co. (“Schwab”) and Fidelity Investment Services (“Fidelity”). WRP IARs maintain the client relationship by handling client questions via telephone, email or in person and by personalizing the service to meet each particular client’s needs for information and assistance. WRP works exclusively with Buckingham as the servicing agent for WRP client accounts. In the three Structured Investing Asset Management Services described below, Buckingham either bills its administrative fee directly to WRP, receives compensation directly from the SA Funds or bills a separate administrative fee to the clients. In the 401(K) services WRP fees and Buckingham fees are billed separately. For certain clients, WRP will retain an independent and unaffiliated separate account manager to perform asset management services with respect to individual stock, fixed income, or other special positions that are applicable to a client’s specific situation. The separate account manager and WRP will work in partnership to manage such positions around other components of the client’s overall portfolio, especially as it relates to tax and volatility parameters. Opening an Account Generally, a written investment plan is prepared for each prospective client before an account will be opened. The written investment plan will define a specific allocation based on the prospective clients’ risk profile as determined using a Risk Questionnaire that reflects the prospective clients’ attitudes toward various types of investment risk and market volatility. Each client’s risk profile is unique to their own circumstances and personal feelings toward risk. Once the client agrees to the Model Portfolio allocation to be used, an account can be opened. Prospective clients are able to open a SAM, Structured Investing Portfolio or Structured Investing Advantage account by taking the following steps: 1. Complete and sign the appropriate account forms (such as Revocable Trust, IRA, UTMA, etc.) as required by the selected custodial firm (eg., Schwab or Fidelity). 2. Sign a managed account relationship agreement naming WRP as the advisor for one of the three portfolio services described above. 3. Sign a Model Portfolio

Allocation form. 4. Deposit funds by check or use transfer forms to move assets from other brokerage firms, mutual funds or bank accounts. Fees are collected on a quarterly basis, usually around the 10th day of the new calendar quarter, using the account values on the last day of the previous calendar quarter. Thus, a portion of the fees are being collected in advance. The fees are computed based on the number of days in that calendar quarter expressed as a percentage of the total days in the year. When accounts are opened, the first billing will be computed on a prorated basis using the number of remaining days that the funds are to be managed that quarter. All fees are collected by debiting the client’s investment account directly and a billing advice memorandum is included with the Performance Reports sent to every client soon after the end of each calendar quarter. Clients utilizing the 401(k) advisory service are charged in arrears. WRP uses a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts (“Held-Away Discretionary Accounts”), with discretion. The platform allows WRP to avoid being considered to have custody of client funds since WRP does not have direct access to client log-in credentials to affect trades. WRP is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is connected to the platform, WRP will review the current account allocations. When deemed necessary, WRP will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. Closing an Account Clients may discontinue these advisory services simply by requesting in writing to do so. In the event a client closes an account, any unearned portion of the fees for the current quarter will be returned to the departing client from the date of account closure until the end of the calendar quarter. Advisory Consulting Services On occasion WRP IARs will prepare a financial plan, a retirement analysis, a 401(K) plan analysis or perform some other advisory consulting service for a client. These functions may be performed at no charge to the client in conjunction with the establishment of an investment advisory account under the SAM, Structured Investing Portfolio or Structured Investing Advantage services. On occasion, however, a WRP IAR may bill a client for these services. In these cases, the client will sign a contract for advisory services before the engagement begins. The contract will detail the exact nature of the services to be performed and the fee for delivering these services. These fees are negotiable and may be quoted on an hourly basis or as a flat fee for specific tasks. The fees will be collected 50% at the time the contract is signed and the remainder payable when the contract services are completed and delivered to the client. Wrap Program WRP does not participate in any wrap programs. ERISA Accounts 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 (“ERISA”) and/or the Internal Revenue Code (the “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. Assets Under Management As of December 31, 2022, WRP managed $767,283,708 in client assets on a discretionary basis and $0 in client assets on a non- discretionary basis.