TWC offers investment management services and wealth planning solutions to high-net-worth clients through its Private Client Program and a la carte wealth planning engagements. Prior to engaging TWC to provide any of the foregoing investment advisory services, a client is required to enter into one or more written agreements with TWC setting forth the terms and conditions under which TWC renders its services (collectively the “Agreement”). TWC has been in business since October 2007. Jeffrey Wheeler is the sole owner of TWC. As of December 31, 2023, TWC discloses approximately $740,090,000 in total assets representing: $669,900,000 of assets under discretionary management in its Asset Management Services; and $70,190,000 plan assets under consultation. Assets under consultation are assets for which TWC acts as a 3(21) or a 3(38) fiduciary and provides ongoing recommendations based upon the needs of the retirement plan client, as to which specific securities or other investments to make available to its plan participants, among other services. This Disclosure Brochure describes the business of TWC. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of TWC’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on TWC’s behalf subject to TWC’s supervision or control. Wealth Planning Services For clients who do not wish to receive ongoing investment management services, TWC may provide its clients with wealth planning services on an a la carte basis. These services include portfolio analysis, budgeting, cash flow planning, retirement planning and estate planning. In performing its services, TWC is not required to verify any information received from the client or the client’s other professionals (e.g., attorney, business manager, accountant, etc.) and is expressly authorized to rely on such information. A client is under no obligation to act upon the recommendations made by TWC under a wealth planning or consulting engagement. TWC may recommend its services and/or the services of other professionals to implement its recommendations. However, a client is under no obligation to engage the services of TWC, or any professional recommended by TWC – the client retains absolute discretion over all such implementation decisions. Clients are advised that a conflict of interest exists if TWC recommends its own services. In reviewing, evaluating, or revising TWC’s previous recommendations and/or reports, clients are advised that it remains their responsibility to promptly notify TWC if there is ever any change in their financial situation or investment objectives that might impact such recommendations or reports. The recommendations made according to the individualized wealth planning services are valid as of the date provided. They should not be considered valid beyond the period stated in the reports. Investment Management Services Clients can engage TWC to manage all or a portion of their assets primarily on a discretionary basis. Depending on the client’s service level, TWC may provide clients with varying degrees of wealth planning services, traditionally referred to in the financial services industry as financial planning services. The centerpiece

of TWC’s services is its Private Client Program, described below in Item 8. The Wealth Collaborative, Inc. Disclosure Brochure TWC primarily allocates clients' investment management assets among mutual and exchange traded funds according to their investment objectives. TWC also provides advice about any investment held in clients' portfolios at the outset of the investment management relationship. TWC tailors its advisory services to the individual needs of clients. TWC consults with clients initially and on an ongoing basis to develop and maintain an investment policy statement that determines risk tolerance, time horizon, and other factors that might impact their investment needs. TWC ensures that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance. Clients are advised to promptly notify TWC if there are changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon TWC’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in TWC’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Use of Independent Managers As described in detail in Item 8, TWC may recommend that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”) based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are outlined in a separate written agreement between the client, the designated Independent Managers and, in some cases, TWC. TWC renders services to the client relative to the discretionary selection or recommendation of Independent Managers. TWC also monitors and reviews the account performance and the client’s investment objectives. TWC receives an annual advisory fee that is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. IRA Rollover Recommendation 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.