A. FIRM INFORMATION Wealthcare Advisory Partners LLC (“WCAP” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). WCAP is organized as a limited liability company (“LLC”) under the laws of the state of Delaware. The predecessor to WCAP was founded in June 2014. WCAP is 100% owned by Wealthcare Parent Holdings LLC (which is principally owned by Financeware LLC and VMS Intermediate Inc.). WCAP is operated by Matthew T. Regan (President), Ronald E. Madey (Chief Investment Officer), James J. Krause (Chief Compliance Officer) and Justin DuBrueler (Chief Financial Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by WCAP. For additional information about our ownership structure, please see our Form ADV Part 1A, Schedules A and B. WCAP offers services through its Advisory Persons. Advisory Persons may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials and/or Client statements. The Client should understand that the businesses are legal entities of the Advisory Person and not of WCAP. The Advisory Persons are under the supervision of WCAP, and the advisory services of Advisory Persons are provided through WCAP. Advisory Persons provide services and charge fees based in accordance with the descriptions detailed in this Disclosure Brochure and the terms of the Client agreement. However, the exact service and fees charged to the Client are dependent upon the Advisory Person that is working with the Client. Advisory Persons are appropriately licensed and authorized to provide advisory services on behalf of WCAP. B. ADVISORY SERVICES OFFERED WCAP offers investment advisory services to individuals, high net worth individuals, trusts, estates, retirement plans, charitable organizations and other businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. WCAP’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. WCAP's mission is to provide sound customized financial advice in the best interest of the Client. For many Clients, the Advisor utilizes a financial advising discipline focused on helping Clients live the one life they have the best way they can. This goals-based financial advisory experience is based upon several U.S. and International patents of Wealthcare Capital Management LLC (“WCM”), a registered investment adviser with the SEC that is affiliated through common ownership. WCM is the first company to provide U.S. and Canadian professional financial advisers and financial institutions with a web‐based, goals-based wealth management software product, and also the first to do so with an integrated simulated market return analysis. Depending on their objectives and needs, some Clients have their needs met by WCAP, and some may have third-party managers, as determined by their individual financial situation and investment objectives. Wealth Management Services WCAP provides tailored investment advisory solutions to its Clients. This is achieved through personal Client contact and interaction while providing discretionary or non-discretionary investment management over Client portfolios and a broad range of comprehensive financial planning. Investment Management and Financial Planning services are also offered as standalone services. These services are described below. Investment Management Services WCAP provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and/or non-discretionary investment management and related advisory services. WCAP works with each investment management Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. WCAP will then design a portfolio with its internal investment strategies, or select from its available models. WCAP will select its portfolios to meet the needs of each Client. Portfolios may be customized to each Client and may include, but are not limited to, mutual funds and exchange-traded funds (“ETFs”), individual stocks, bonds and alternative investments. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Alternative Investments – As noted above, certain models may include the use of alternative investments when deemed appropriate and in the Client’s best interest. Investing directly in hedge funds, private equity, and/or real estate funds can be difficult for many individuals given due diligence requirements, portfolio construction complexity, large minimum investments which limit an individual’s ability to diversify his/her investments, restrictive liquidity terms, and other access limitations. To help offset these potential barriers to entry into these types of investment opportunities, WCAP engages with alternative investment platforms to: (i) provide due diligence resources and services; (ii) facilitate access to managers at lower minimums; and (iii) structure multi-manager private investment solutions that allow WCAP qualified clients to access relatively diversified and carefully constructed pools of institutional- quality alternative investments, including hedge funds and private equity and real asset funds, managed by unaffiliated investment advisers. WCAP structures these opportunities by leveraging third-party platform resources (investment research, risk management, legal and operational due diligence) to supplement its in- house resources. Through these third-party platforms, WCAP can offer single strategy and multi-strategy investments in a private fund construct, a private fund-of-funds construct, or a custom private multi-strategy portfolio (e.g..: arbitrage; credit; equity long/short; global macro; event driven; private equity; and real estate) using private limited liability companies or limited partnerships that are exempt from registration under federal securities regulations, including the Investment Company Act of 1940 (the “Investment Company Act”) and the Securities Act of 1933 (the “Securities Act”).Investment in these alternative investments is limited to persons who are “accredited investors” as defined under the Securities Act and, depending on the fund, “qualified purchasers” as defined in the Investment Company Act. Clients should refer to the private placement memoranda and class supplement documents, as well as the underlying funds’ private placement memoranda, for a more complete discussion of these investments. Delaware Statutory Trusts (“DSTs”) – When appropriate Advisors of WCAP will recommend to accredited investor Client’s investment in DSTs. Investments in DSTs are billed as assets undermanagement and follow the billing schedule identified in Item 5 and agreed upon by Clients in their advisory agreement. WCAP’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. WCAP will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. WCAP evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. WCAP may recommend, on occasion, redistributing investment allocations to diversify the portfolio. WCAP may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or over-weighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will WCAP accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement. Please see Item 12 – Brokerage Practices. Use of Affiliated Manager – Under the discretionary authority granted to WCAP, Clients may be referred to utilize the portfolio management services of WCM for all or a portion of the Client’s portfolio. Please see Item 10 for additional information. The Client will be provided with WCM’s Form ADV Part 2A (or a brochure that makes the appropriate disclosures) of those parties. Selection of Other Advisor – Additionally, WCAP may recommend Assetmark, Inc. (“AssetMark”) for investment advisory services. WCAP will receive a portion of the investment advisory fee for the solicitation and referral of the Client to AssetMark, and may assist the Client in completing their Client questionnaire and account opening paperwork. WCAP may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. Use of Independent Managers and Managed Account Programs - WCAP may also recommend to Clients that all or a portion of their investment portfolio

be implemented by utilizing one or more unaffiliated money managers/investment platforms (collectively “Independent Managers”), which are available through the recommended Custodians. The Advisor may also utilize an unaffiliated money manager participating in a turnkey asset management program (“TAMP”). The Client may be required to enter into a separate agreement with the Independent Manager[s]. In these instances, WCAP serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. WCAP will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. WCAP will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties. For Client’s whose assets are placed in a TAMP, the Client will enter into a program and investment advisory agreement with the TAMP (the “Program Sponsor”) and the participating money manager[s]. The Advisor will assist and advise the Client in establishing investment objectives for the account[s], the selection of the money manager[s], and defining any restrictions on the account[s] and determining any changes to portfolio strategy. WCAP will provide ongoing oversight of the Client accounts and the activities of the unaffiliated money managers selected to manage the Client’s assets. These money managers will develop an investment strategy to meet those objectives by identifying appropriate investments and monitoring such investments. In consideration for such services, the Program Sponsor will charge a program fee that includes the investment advisory fee of the money managers, the administration of the program and trading, clearance and settlement costs. The Program Sponsor will add WCAP’s investment advisory fee (described below in Item 5) and will deduct the overall fee from the Client’s account[s], pursuant to the agreement between the Program Sponsor and the Client. The Client, prior to entering into an agreement with an Independent Manager and/or Program Sponsor, will be provided with the Form ADV Part 2A (or a brochure that makes the appropriate disclosures) of those parties. WCAP does not receive any compensation from these Independent Managers or Investment Platforms, other than WCAP’s investment advisory fee, as described in Item 5. Non-Purpose Loans - The Advisor introduces certain Clients to a non-purpose loan program made available through a Custodian’s banking partner affiliate (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Financial Planning and Consulting Services WCAP will typically provide a variety of financial planning and consulting services to individuals and families, either as a component of wealth management services or pursuant to a written financial planning or consulting agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. WCAP may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a potential conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services WCAP provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Due Diligence and Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Ongoing Investment Recommendation and Assistance These services are provided by WCAP serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of WCAP’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. CLIENT ACCOUNT MANAGEMENT Prior to engaging WCAP to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: § Establishing an Investment Strategy – WCAP, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. § Asset Allocation – WCAP will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. § Portfolio Construction – WCAP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. § Investment Management and Supervision – WCAP will provide investment management and ongoing oversight of the Client’s investment portfolio. D. WRAP FEE PROGRAM For some Clients, WCAP may include the securities transaction fees together with investment advisory fees to provide the Client with a single, bundled fee structure. This combination of fees is typically referred to as a “Wrap Fee Program”. WCAP customizes its investment management services for Clients. This Wrap Fee Program Brochure is included as Appendix 1 to this Disclosure Brochure solely to discuss the fees and potential conflicts associated with a bundled fee. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is always included with this Disclosure Brochure. Additionally, WCAP may recommend the investment strategies of various third-party advisors (“TPAs”) to its Clients. The TPA selected may offer a model portfolio that is available as part of a wrap fee program. In such instances, the wrap fee agreement is inclusive of the TPA’s fee and custody fees. If a TPA’s wrap fee program is selected for a Client’s account, the wrap fee program brochure for the TPA’s program will be presented to the Client. The wrap fee program brochure will describe the investment strategy as well as the fees and services performed by the program manager. In some instances, WCAP Advisory Persons have Client relationships which are held at wrap fee sponsors, such as Lockwood, in which a TPA is managing the Client assets. Those relationships generally predate the IAR’s affiliation with WCAP and remain as is, if it is deemed to be in the Client’s best interests. E. ASSETS UNDER MANAGEMENT As of December 31, 2023, WCAP manages $4,541,661,225 in Client assets, $4,285,232,689 of which is on a discretionary basis and $256,428,536 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.