Advocacy Wealth Management, LLC (“Advocacy Wealth”) was established and approved as a Registered Investment Adviser with the SEC in January 2007. Forge Consulting, LLC (“Forge”) is the sole owner of Advocacy Wealth. Advocacy Wealth will strive at all times to do no harm to you the client and act in your best interests at all times and without exception. (Hereafter, “you” and “your” refer to the individual client or client. “We” and “our” refer to Advocacy Wealth.) Portfolio Management Advocacy Wealth offers investment advisory services to corporations, individuals, trusts, charities and estates. Advice and services are tailored to your stated objectives. Advocacy Wealth Investment Adviser Representatives (our “Financial Advisors”) work with you to identify your investment goals and objectives, as well as risk tolerance, to create an initial portfolio allocation designed to complement your financial plan. The portfolio could consist of equities, income securities, mutual funds, options, and alternative investments. Generally, we create a limited financial plan at the least in connection with the initial portfolio allocation for an individual. In certain circumstances, we do accept restrictions on ownership or retention of certain securities by the clients themselves. We strongly advise individual clients that should your financial situation or investment goals or objectives change, you must notify Advocacy Wealth promptly of those changes. Advocacy Wealth manages the investments of trusts, which can be, though are not limited to, grantor, settlement, or testamentary in origin, on either a directed or a delegated basis. In a delegated relationship, Advocacy Wealth receives instructions from the trustee(s) for investment parameters and authority. In a directed relationship, Advocacy Wealth has full investment discretion and authority granted to it by the terms of the trust agreement. In general, trusts under management by Advocacy Wealth tend to seek asset conservation as a primary objective, income from the invested assets as a secondary objective, and growth as a tertiary objective. Until recently, persistent low levels of interest rates had required achieving secondary and tertiary objectives through total return. At the present time, the majority of Advocacy Wealth clients are recipients of a personal injury, wrongful death, or workers compensation settlements as well as their plaintiff attorneys. Many of these accounts have an annuity component and a cash component to them. Advocacy Wealth manages the cash component, as well as the overall financial well-being – to the extent possible – of the individual client. Advocacy Wealth works with its owner, the general insurance agency, Forge Consulting, LLC, to design a financial plan to promote financial well-being, including our clients who are not sourced from litigation. We define financial well-being as using our resources and advice to help a client find solutions for health, education, maintenance and support. Advocacy Wealth continues to monitor, modify and adjust as life situations, investment opportunities, and objectives change. While the investments are being managed, the Advocacy Wealth service staff, affiliates, and outside partners help clients buy houses and vehicles, medical equipment, find affordable insurance and other items necessary to support the client’s well-being as part of an overall financial plan. Advocacy Wealth provides resources to help preserve governmental benefits. Advocacy Wealth does not charge an extra fee for any of these services. Financial Planning Advocacy Wealth will prepare and provide clients, upon request, a written financial plan designed to help them achieve their financial goals and investment objectives. The preparation of such a plan necessitates that the client provides Advocacy Wealth with personal data such as family records, budgeting, personal liability, estate information and additional financial goals. There is no additional charge to the client for the preparation of the financial plan if Advocacy Wealth is paid to manage the client’s investments. The financial plan can include any or all of the following upon request and/or as directed by the client: asset protection, tax planning, cash flow, insurance planning, asset allocation comparisons and risk management, long-term care and disability planning, education planning, retirement planning, estate planning and wealth transfer, charitable gifting, 401k plan evaluation, business succession and strategies for exercising stock options. Should a client choose to implement the recommendations contained in the financial plan, Advocacy Wealth strongly recommends that clients work closely with their attorney, accountant, insurance agent, and/or other financial advisors. Clients are not under any obligation to engage Advocacy Wealth when considering implementation of advisory recommendations. The client decides whether to implement any or all recommendations, which is solely at the discretion of and can be implemented through another Registered Investment Adviser. Advocacy Wealth Financial Advisor can also be licensed to sell life, health and group insurance as well as property and casualty through an affiliated insurance agency, Forge Consulting LLC. Clients are under no obligation to utilize services of associated persons in the purchase or sales of insurance products. However, if transactions are conducted through Advocacy Wealth’s affiliate, Forge Consulting LLC, then commissions and/or overrides will be earned by Forge in addition to any advisory fees charged by Advocacy Wealth. If a Trust is administered by Advocacy Trust, our affiliated Trust company will earn fees for that administration, whether Advocacy Wealth manages the investments or not. Advocacy Trust may invest available cash awaiting investment or distribution held in certain trust accounts in FDIC insured money market bank accounts. These accounts are selected by Advocacy Trust. In exchange for providing master account services to the depository institution for balances held in FDIC insured money market bank accounts, Advocacy Trust receives an interest concession from the depository institution. This interest concession is forty percent (40%) of the total interest payment, but at no time will the amount received by Advocacy Trust exceed fifty one-hundredths of one percent (0.50 of 1% = 0.005) per annum of the net assets invested. From time to time, clients will ask Advocacy Wealth to design or review a financial plan for which neither Advocacy Wealth nor its affiliates will otherwise receive compensation. In such cases, Advocacy Wealth reserves the right to charge a fee commensurate with the work to be done with the approval of the client before work commences. On December 15, 2020 the Department of Labor (“DOL”) issued its final interpretation of fiduciary under ERISA and the Internal Revenue Code as well a new class exemption, Prohibited Transaction Exemption (“PTE”) 2020-02. To receive compensation that might otherwise be considered a prohibited transaction, PTE 2020-02, which became effective February 16, 2021 and enforceable January 31, 2022, requires fiduciaries to comply with the following impartial conduct standards: 1. The fiduciary must provide advice in the “Best Interest” of the Retirement Investor 2. The fiduciary must charge “reasonable” compensation for the services provided 3. The fiduciary must make only “not misleading” statements about investment transactions, compensation, and conflicts of interest. 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 (PTE 2020-02), 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. As of December 31, 2023, Advocacy Wealth held $1,706,997,924 in discretionary assets and $16,823,388 in non-discretionary assets under management. Standard of Care Advocacy Wealth affirms its fiduciary duty to serve its clients’ best interests before its own. Advocacy Wealth assents that the investment adviser’s fiduciary duty under the Investment Advisers Act of 1940 (“Advisers Act”) comprises a duty of care and a duty of loyalty. This fiduciary duty means the adviser must, at all times, serve the best interest of its clients and not subordinate its clients’ interest to its own. The federal fiduciary duty is imposed through the antifraud provisions of the Advisers Act. The duty follows the contours of the relationship between the adviser and its client, and the adviser and its client may shape that relationship through contract when the client receives full and fair disclosure and provides informed consent. Although the ability to tailor the terms means that the application of the fiduciary duty will vary with the terms of the relationship, the relationship in all cases remains that of a fiduciary to a client. In other words, the investment adviser cannot disclose or negotiate away, and the investor cannot waive, the federal fiduciary duty. A. Duty of Care As fiduciaries, investment advisers owe their clients a duty of care. The duty of care includes, among other things: (1) the duty to act and to provide advice that is in the best interest of the client, (2) the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades, and (3) the duty to provide advice and monitoring over the course of the relationship. i. Duty to Provide Advice that is in the Client’s Best Interest In this context, the duty of care includes a duty to make a reasonable inquiry into a client’s financial situation, level of financial sophistication, investment experience, and investment objectives (collectively, the client’s “investment profile”) and a duty to provide personalized advice that is suitable for and in the best interest of the client based on the client’s investment profile. An adviser must, before providing any personalized investment advice and as appropriate thereafter, make a reasonable inquiry into the client’s investment profile. The nature and extent of the inquiry turn on what is reasonable under the circumstances, including the nature and extent of the agreed-upon advisory services, the nature and complexity of the anticipated investment advice, and the investment profile of the client. For example, to formulate a comprehensive financial plan for a client, an adviser might obtain a range of personal and financial information about the client, including current income, investments, assets and debts, marital status, insurance policies, and financial goals. An adviser must update a client’s investment profile in order to adjust its advice to reflect any changed circumstances. The frequency with which the adviser must update the information in order to consider changes to any advice the adviser provides would turn on many factors, including whether the adviser is aware of events that have occurred that could render inaccurate or incomplete the investment profile on which it currently bases its advice. For example, a change in the relevant tax law or knowledge that the client has retired or experienced a change in marital status might trigger an obligation to make a new inquiry. An investment adviser must also have a reasonable belief that the personalized advice is suitable for and in the

best interest of the client based on the client’s investment profile. A reasonable belief would involve considering, for example, whether investments are recommended only to those clients who can and are willing to tolerate the risks of those investments and for whom the potential benefits may justify the risks. Whether the advice is in a client’s best interest must be evaluated in the context of the portfolio that the adviser manages for the client and the client’s investment profile. For example, when an adviser is advising a client with a conservative investment objective, investing in certain derivatives may be in the client’s best interest when they are used to hedge interest rate risk in the client’s portfolio, whereas investing in certain directionally speculative derivatives on their own may not. For that same client, investing in a particular security on margin may not be in the client’s best interest, even if investing in that same security may be in the client’s best interest. When advising a financially sophisticated investor with a high-risk tolerance, however, it may be consistent with the adviser’s duties to recommend investing in such directionally speculative derivatives or investing in securities on margin. The cost (including fees and compensation) associated with investment advice would generally be one of many important factors—such as the investment product’s or strategy’s investment objectives, characteristics (including any special or unusual features), liquidity, risks and potential benefits, volatility and likely performance in a variety of market and economic conditions—to consider when determining whether a security or investment strategy involving a security or securities is in the best interest of the client. Accordingly, the fiduciary duty does not necessarily require an adviser to recommend the lowest cost investment product or strategy. Advocacy Wealth will not recommend that a security is in the best interest of a client if it is higher cost than a security that is otherwise identical, including any special or unusual features, liquidity, risks and potential benefits, volatility and likely performance. For example, if an adviser advises its clients to invest in a mutual fund share class that is more expensive than other available options when the adviser is receiving compensation that creates a potential conflict and that may reduce the client’s return, the adviser may violate its fiduciary duty and the antifraud provisions of the Advisers Act if it does not, at a minimum, provide full and fair disclosure of the conflict and its impact on the client and obtain informed client consent to the conflict. Furthermore, an adviser would not satisfy its fiduciary duty to provide advice that is in the client’s best interest by simply advising its client to invest in the least expensive or least remunerative investment product or strategy without any further analysis of other factors in the context of the portfolio that the adviser manages for the client and the client’s investment profile. For example, it might be consistent with an adviser’s fiduciary duty to advise a client with a high risk tolerance and significant investment experience to invest in a private equity fund with relatively high fees if other factors about the fund, such as its diversification and potential performance benefits, cause it to be in the client’s best interest. Investment advice that is in the best interest of a client also requires that an adviser conduct a reasonable investigation into the investment sufficient to not base its advice on materially inaccurate or incomplete information. This obligation to provide advice that is suitable and in the best interest applies not just to potential investments, but to all advice the investment adviser provides to clients, including advice about an investment strategy or engaging a sub-adviser and advice about whether to rollover a retirement account so that the investment adviser manages that account. ii. Duty to Seek Best Execution An investment adviser’s duty of care in the context of trade execution where the adviser has the responsibility to select broker-dealers to execute client trades (typically in the case of discretionary accounts) has to seek best execution of a client’s transactions. In meeting this obligation, an adviser must seek to obtain the execution of transactions for each of its clients such that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. An adviser fulfills this duty by executing securities transactions on behalf of a client with the goal of maximizing value for the client under the particular circumstances occurring at the time of the transaction. As noted below, maximizing value can encompass more than just minimizing cost. When seeking best execution, an adviser should consider “the full range and quality of a broker’s services in placing brokerage including, among other things, the value of research provided as well as execution capability, commission rate, financial responsibility, and responsiveness” to the adviser. In other words, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution. Further, an investment adviser should “periodically and systematically” evaluate the execution it is receiving for clients. iii. Duty to Act and to Provide Advice and Monitoring over the Course of the Relationship An investment adviser’s duty of care also encompasses the duty to provide advice and monitoring over the course of a relationship with a client. An adviser is required to provide advice and services to a client over the course of the relationship at a frequency that is both in the best interest of the client and consistent with the scope of advisory services agreed upon between the investment adviser and the client. The duty to provide advice and monitoring is particularly important for an adviser that has an ongoing relationship with a client (for example, a relationship where the adviser is compensated with a periodic asset-based fee or an adviser with discretionary authority over client assets). Conversely, the steps needed to fulfill this duty may be relatively circumscribed for the adviser and client that have agreed to a relationship of limited duration via contract (for example, a financial planning relationship where the adviser is compensated with a fixed, one-time fee commensurate with the discrete, limited-duration nature of the advice provided). An adviser’s duty to monitor extends to all personalized advice it provides the client, including an evaluation of whether a client’s account or program type continues to be in the client’s best interest. B. Duty of Loyalty The duty of loyalty requires an investment adviser to put its client’s interests first. An investment adviser must not favor its own interests over those of a client or unfairly favor one client over another. In seeking to meet its duty of loyalty, an adviser must make full and fair disclosure to its clients of all material facts relating to the advisory relationship. In addition, an adviser must seek to avoid conflicts of interest with its clients, and, at a minimum, make full and fair disclosure of all material conflicts of interest that could affect the advisory relationship. The disclosure should be sufficiently specific so that a client is able to decide whether to provide informed consent to the conflict of interest. Because an adviser must serve the best interests of its clients, it has an obligation not to subordinate its clients’ interests to its own. For example, an adviser cannot favor its own interests over those of a client, whether by favoring its own accounts or by favoring certain client accounts that pay higher fee rates to the adviser over other client accounts. Accordingly, the duty of loyalty includes a duty not to treat some clients favorably at the expense of other clients. When allocating investment opportunities among eligible clients, an adviser must treat all clients fairly. This does not mean that an adviser must have a pro rata allocation policy, that the adviser’s allocation policies cannot reflect the differences in clients’ objectives or investment profiles, or that the adviser cannot exercise judgment in allocating investment opportunities among eligible clients. Rather, it means that an adviser’s allocation policies must be fair and, if they present a conflict, the adviser must fully and fairly disclose the conflict such that a client can provide informed consent. An adviser must seek to avoid conflicts of interest with its clients, and, at a minimum, make full and fair disclosure to its clients of all material conflicts of interest that could affect the advisory relationship. Disclosure of a conflict alone is not always sufficient to satisfy the adviser’s duty of loyalty and section 206 of the Advisers Act. Any disclosure must be clear and detailed enough for a client to make a reasonably informed decision to consent to such conflicts and practices or reject them. An adviser must provide the client with sufficiently specific facts so that the client is able to understand the adviser’s conflicts of interest and business practices well enough to make an informed decision. For example, an adviser disclosing that it “may” have a conflict is not adequate disclosure when the conflict actually exists. A client’s informed consent can be either explicit or, depending on the facts and circumstances, implicit. It would not be consistent with an adviser’s fiduciary duty to infer or accept client consent to a conflict where either (i) the facts and circumstances indicate that the client did not understand the nature and import of the conflict, or (ii) the material facts concerning the conflict could not be fully and fairly disclosed. For example, in some cases, conflicts may be of a nature and extent that it would be difficult to provide disclosure that adequately conveys the material facts or the nature, magnitude and potential effect of the conflict necessary to obtain informed consent and satisfy an adviser’s fiduciary duty. In other cases, disclosure may not be specific enough for clients to understand whether and how the conflict will affect the advice they receive. With some complex or extensive conflicts, it may be difficult to provide disclosure that is sufficiently specific, but also understandable, to the adviser’s clients. In all of these cases where full and fair disclosure and informed consent is insufficient, an adviser must eliminate the conflict or adequately mitigate the conflict so that it can be more readily disclosed. Full and fair disclosure of all material facts that could affect an advisory relationship, including all material conflicts of interest between the adviser and the client, can help clients and prospective clients in evaluating and selecting investment advisers. Form CRS provides a brief relationship summary designed to help retail investors make informed choices regarding what type of relationship—brokerage, investment advisory, or a combination of both—best suits a retail investor’s particular circumstances and investment objectives. The relationship summary is intended to promote transparency, comparability and better-informed decision-making, through clear, concise disclosures, and by summarizing in one place selected information about a particular firm. This format is designed to allow retail investors to more easily compare different firms’ services, fees, conflicts of interest, disciplinary history and other important information. In addition, Advisers must deliver another document to their clients, known as the “brochure,” under Part 2A of Form ADV, which sets out minimum disclosure requirements, including disclosure of certain conflicts. Investment advisers are required to deliver the brochure to a prospective client at or before entering into a contract so that the prospective client can use the information contained in the brochure to decide whether or not to enter into the advisory relationship. An offer of an updated brochure must be made to each client annually.