Investment Adviser Policies and Procedures Manual Docs... · Wealth Management LLC IA Policies and Procedures Manual 1/1/2015 to Current Description of Firm Wealth Management LLC,

Wealth Management LLC Investment Adviser

Policies and Procedures Manual

Wealth Management LLC IA Policies and Procedures Manual

1/1/2015 to Current

Table of Contents

1 - Description of Firm

2 – Introduction

3 – Advertising

4 – Advisory Agreement

5 – Agency Cross Transactions

6 – Annual Compliance Reviews

7 – Anti-Money Laundering

8 – Best Execution

9 – Books and Records

10 - Client Communications and Correspondence

11- Client Fees

12 – Complaints

13 – Corporate Records

14 - Custody

15 – Directed Brokerage

16 – Disaster Recovery

17 – Disclosure Document

18 - Discretionary Authority

19 – E-Mail and Other Electronic Communications

20 – ERISA

21 - Fiduciary Duty

22- Foreign Client Accounts

23 - Gifts & Entertainment

24 - Identity Theft Prevention (Red Flag Rules)

25 - Information Security Plan

26 – Insider Trading

27 – Investment Processes

28 - Outside Business Activities

29 – Performance

30 – "Pay to Play" Political Contributions

31 – Code of Ethics

32 - Personal Securities Transactions & Records

33 - Principal Trading

34 – Privacy

35 – Proxy Voting

36 – Registration

37 - Regulatory Examinations

38 – Regulatory Reporting

39 – Soft Dollars

40 – Solicitor Arrangements

41 – Supervision & Internal Controls

42 – Trading

43 – Valuations of Securities

44 - Whistleblower Complaints

45 – Wrap Fee Advisor

46 – Wrap Fee Sponsor


1/1/2015 to Current

Description of Firm Wealth Management LLC, (a Nebraska Limited Liability Company) is a registered investment advisor firm. Wealth Management LLC is located with and associated with the accounting firm of Christensen Brozek Faltys PC at 125 South 4th Street, Norfolk, Nebraska. Wealth Management LLC is owned by a holding company corporation named Wealth Management Holdings, Inc. (a Nebraska Corporation). The Investment Advisor Representatives associated with Wealth Management LLC work from this same location and from other locations throughout the United States. Wealth Management LLC does not act as an advisor on individual stocks, but rather provides advisor services on no-load mutual funds, ETF’s (exchange traded funds), and allows clients to hold individual stocks and bonds as they request in their accounts. Wealth Management LLC does not provide brokerage services to its clients. Wealth Management LLC is a fee-only advisor, and uses T.D. Ameritrade and Aegon as custodians for client accounts. T.D. Ameritrade does charge trade fees on client transactions. Aegon has a fee structure based upon the guarantees on returns requested by the client. The greater the guarantee amount at death of the annuitant on the annuity contract; the greater the fee charged.


1/1/2015 to Current

Introduction

Policy

Wealth Management LLC is a registered investment adviser with the U.S. Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940 (Advisers Act).

Our firm has a strong reputation based on the professionalism and high standards of the firm and our employees. The firm’s reputation and our advisory client relationships is the firm’s most important asset.

As a registered adviser, and as a fiduciary to our advisory clients, our firm has a duty of loyalty and to always act in utmost good faith, place our clients’ interests first and foremost and to make full and fair disclosure of all material facts and in particular, information as to any potential and/or actual conflicts of interests.

As a SEC registered adviser, Wealth Management LLC and our employees are also subject to various requirements under the Advisers Act and rules adopted under the Advisers Act and our Code of Ethics. These requirements include various anti-fraud provisions, which make it unlawful for advisers to engage in any activities which may be fraudulent, deceptive or manipulative.

These antifraud provisions include the SEC Compliance Programs of Investment Companies and Investment Advisers (Compliance Programs Rule) (SEC Rule 206 (4)-7) which requires advisers to adopt a formal compliance program designed to prevent, detect and correct any actual or potential violations by the adviser or its supervised persons of the Advisers Act, and other federal securities laws and rules adopted under the Advisers Act.

Elements of Wealth Management LLC's compliance program include the designation of a Chief Compliance Officer, adoption and annual reviews of these IA Compliance Policies and Procedures, training, and recordkeeping, among other things.

Our IA Policies and Procedures cover Wealth Management LLC and each officer, member, or partner, as the case may be, and all employees who are subject to Wealth Management LLC 's supervision and control (Supervised Persons).

Our IA Policies and Procedures are designed to meet the requirements of the SEC IA Compliance Wealth Management LLC Program Rule and to assist the firm and our Supervised Persons in preventing, detecting and correcting violations of law, rules and our policies.

Our IA Policies and Procedures cover many areas of the firm’s businesses and compliance requirements. Each section provides the firm’s policy on the topic and provides our firm’s procedures to insure that the particular policy is followed.

Wealth Management LLC 's Chief Compliance Officer is responsible for administering our IA Policies and Procedures.

Compliance with the firm’s IA Policies and Procedures is a requirement and a high priority for the firm and each person. Failure to abide by our policies may expose you and/or the firm to

significant consequences which may include disciplinary action, termination, regulatory sanctions, potential monetary sanctions and/or civil and criminal penalties.

The Chief Compliance Officer will assist with any questions about Wealth Management LLC's IA Policies and Procedures, or any related matters. Further, in the event any employee becomes aware of, or suspects, any activity that is questionable, or a violation, or possible violation of law, rules or the firm’s policies and procedure, the Chief Compliance Officer is to be notified immediately.

Our IA Policies and Procedures will be updated on a periodic basis to be current with our business practices and regulatory requirements. The Chief Compliance Officer and/or designated person(s) will review and update the firm's IA Policies and Procedures Manual. The firm's IA Policies and Procedures manual will be distributed to each person considered to be an access person or Investment Advisor Representative, at least annually, upon being hired, or when substantial changes are made in its content. Insignificant changes that are made will be addressed either by electronic notification, or in a meeting, or both. The Chief Compliance Officer or someone directed by him will provide such notification and/or distribution. Written acknowledgements will be received by the Chief Compliance Officer regarding receipt, review, understanding, and agreement to comply with the firm's IA Policies and Procedures from all access persons and Investment Advisor Representatives at least annually, upon being hired, or when substantial changes are made in its content.


1/1/2015 to Current

Advertising

Policy

Wealth Management LLC uses various advertising and marketing materials to obtain new advisory clients and to maintain existing client relationships. Wealth Management LLC 's policy requires that any advertising and marketing materials must be truthful and accurate, consistent with applicable rules, and reviewed and approved by a designated officer. Wealth Management LLC 's policy prohibits any advertising or marketing materials that may be misleading, fraudulent, deceptive and/or manipulative.

Background

An advertisement is generally defined as any written communication, which includes websites and e-mails, directed to more than one person concerning advice or recommendations about the purchase or sale of securities or any other advisory service. The SEC anti-fraud rules under the Advisers Act prohibit advisers from engaging in advertising practices which are fraudulent, deceptive, or manipulative activities. The manner in which investment advisers portray themselves, services and their investment returns to existing and prospective clients is highly regulated. SEC no-action letters also provide guidelines and prohibitions relating to an adviser's advertising and marketing practices.

Responsibility

Larry E. Hilkemann has the responsibility for implementing and monitoring our policy, and for reviewing and approving any advertising and marketing to insure any materials are consistent with our policy and regulatory requirements. This designated person is also responsible for maintaining, as part of the Wealth Management LLC 's books and records, copies of all advertising and marketing materials with a record of reviews and approvals in accordance with applicable recordkeeping requirements.

Procedure

Wealth Management LLC has adopted procedures to implement the firm’s policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

All advertisements and promotional materials must be reviewed and approved prior to use by The Internal Operations Manager, the Chief Compliance Officer, the Internal Operations Manager, a designated officer, President, or another officer of the firm (other than the individual who prepared such material).

The initialing and dating of the advertising and marketing materials will document approval.

Each employee is responsible for ensuring that only approved materials are used and that approved materials are not modified without the express written approval of Chief Compliance Officer or the designated officer.

Each employee is responsible for ensuring that when approved materials are used in a presentation to a client or prospective client that the information along with footnote disclosures are both presented to the client or prospective client and a copy offered to them.

The Chief Compliance Officer or a designee must also review other written communications prepared for existing clients or prospective clients including any quarterly letters.

The Chief Compliance Officer, or a designee, is responsible for maintaining copies of any advertising and marketing materials, including any reviews and approvals, for a total period of five years following the last time any material is disseminated.

Advertising cannot contain untrue statements of material facts or any statement that is

false or misleading.

Advertising cannot contain any guarantees (or promises) or include language that can be construed as a guarantee.

Advertising materials cannot contain any statements, graphs or charts that cannot be fully

supported, sourced or documented.

When presenting an opinion, the advertising material must already indicate the statement is an opinion or assumption of Wealth Management LLC and not presented as fact.

Advertising materials should not include "absolute" language that cannot be proven.

Examples are: "all", "every", "none", "best", and "worst". Usually "absolute" statements can be amended so not to be interpreted as an "absolute" statement.

Advertising materials cannot refer directly or indirectly, to a testimonial of any kind

concerning Wealth Management LLC or any advice, analysis, report, or other service it provides.

The SEC prohibits an advisor from representing or implying that it has been approved or

endorsed by the SEC. When creating advertising materials, supervised persons are not allowed to use the designation of "RIA", "IA", or "IAR" after Wealth Management LLC's name or after the name of any investment advisor representative associates with it.


1/1/2015 to Current

Advisory Agreement

Policy

Wealth Management LLC 's policy requires a written investment advisory agreement for each client relationship which includes a description of our services, discretionary/non-discretionary authority, advisory fees, important disclosures and other terms of our client relationship. Wealth Management LLC 's advisory agreements meet all appropriate regulatory requirements and contain a non-assignment clause and do not contain any “hedge clauses.” As part of Wealth Management LLC 's policy, the firm also obtains important relevant and current information concerning the client’s identity, occupation, financial circumstances and investment objectives, among many other things, as part of our advisory and fiduciary responsibilities.

Background

Written advisory agreements form the legal and contractual basis for an advisory relationship with each client and as a matter of industry and business best practices provide protections for both the client and an investment adviser. An advisory agreement is the most appropriate place for an adviser to describe its advisory services, fees, liability, and disclosures for any conflicts of interest, among other things. It is also a best business practice to provide a copy of the advisory agreement to the client and for the agreement to provide for all client financial and personal information to be treated on a confidential basis.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of the firm’s advisory agreement policy, practices, disclosures and recordkeeping.

Procedure


Wealth Management LLC's advisory agreements and advisory fee schedules, and any changes, for the firm’s services are approved by management.

The fee schedules are periodically reviewed by Wealth Management LLC to be fair, current and competitive.

A designated officer, or the Compliance Officer, periodically reviews the firm’s disclosure brochure, marketing materials, advisory agreements and other material for accuracy and consistency of disclosures regarding advisory services and fees.

Performance-based fee arrangements, if any, are appropriately disclosed, reviewed and approved by the designated officer and/or management.

Written client investment objectives or guidelines are obtained, or recommended as part of a client's advisory agreement.

Client investment objectives or guidelines are monitored on an on-going and also periodic basis for consistency with client investments/portfolios.

Any solicitation/referral arrangements and solicitor/referral fees must be in writing, reviewed and approved by the designated officer and/or management, meet regulatory requirements and appropriate records maintained.

Any additional compensation arrangements are to be monitored by the designated officer, or Compliance Officer, approved and disclosed with appropriate records maintained.


1/1/2015 to Current

Agency Cross Transactions

Policy

Wealth Management LLC 's policy and practice is to NOT engage in any agency cross transactions and our firm’s policy is appropriately disclosed in Form ADV Part I and II responses.

Background

An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction (SEC Rule 206(3)-2(b)). Agency cross transactions typically may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Agency cross transactions are permitted for advisers only if certain conditions are met under Advisers Act rules including prior written consent, client disclosures regarding trade information and annual disclosures, among other things.

Responsibility

Larry E. Hilkemann has the overall responsibility for implementing and monitoring our policy of not engaging in any agency cross transactions.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm's policy and reviews to monitor and insure the firm's policy is observed, implemented properly and amended or updated as appropriate, which include the following:

Wealth Management LLC policy of prohibiting any agency cross transactions for advisory clients has been communicated to relevant individuals including portfolio managers, traders and others.

The policy is appropriately disclosed in the firm's Form ADV. Larry E. Hilkemann periodically monitors the firm's advisory services and trading practices

to help insure that no agency cross transactions occur for advisory clients. In the event of any change in the firm's policy, any such change must be approved by

management, any agency cross transactions would only be allowed after appropriate authorizations, reviews, approvals, disclosures, reporting and meeting appropriate regulatory requirements and maintaining proper records.


1/1/2015 to Current

Annual Compliance Reviews

Policy

As a SEC registered adviser, it is Wealth Management LLC 's policy to conduct an annual review of the firm’s policies and procedures to determine that they are adequate, current and effective in view of the firm’s businesses, practices, advisory services, and current regulatory requirements. Our policy includes amending or updating the firm’s policies and procedures to reflect any changes in the firm’s activities, personnel, or regulatory developments, among other things, either as part of the firm’s annual review, or more frequently, as may be appropriate, and to maintain relevant records of the annual reviews.

Background

In December 2003, the SEC adopted new rule 206(4)-7, Compliance Programs of Investment Companies and Investment Advisers (Compliance Program Rule) under the Advisers Act and Investment Company Act, (SEC Release Nos. IA-2204 and IC-26299). The new rules are effective and advisers and funds had to be in compliance with the new rules by 10/5/2004. The rules require SEC registered advisers and investment companies to adopt and implement written policies and procedures designed to detect and prevent violations of the federal securities laws. The new rules are also designed to protect investors by ensuring all funds and advisers have internal programs to enhance compliance with the federal securities laws. Among other things, the rules require that advisers and investment companies annually review their policies and procedures for their adequacy and effectiveness and maintain records of the reviews. A Chief Compliance Officer must also be designated by advisers and investment companies to be responsible for administering the compliance policies, procedures and the annual reviews.

The required reviews are to consider any changes in the adviser’s or fund’s activities, any compliance matters that have occurred in the past year and any new regulatory requirements or developments, among other things. Appropriate revisions of a firm’s or fund’s policies or procedures should be made to help insure that the policies and procedures are adequate and effective. Advisers and funds must complete their first annual review within eighteen months of the adoption or approval of their compliance policies and procedures (i.e. no later than April 5, 2006, and annually thereafter).

Responsibility

Larry E. Hilkemann, Chief Compliance Officer, has the overall responsibility and authority to develop and implement the firm’s compliance policies and procedures and to conduct an annual review to determine their adequacy and effectiveness in detecting and preventing violations of the firm’s policies, procedures or federal securities laws. Larry E. Hilkemann also has the responsibility for maintaining relevant records regarding the policies and procedures and documenting the annual reviews.

Procedure


On at least an annual basis, Larry E. Hilkemann, and such other persons as may be designated, will undertake a complete review of all Wealth Management LLC 's written compliance policies and procedures.

The review will include a review of each policy to determine the following:

(a) adequacy; (b) effectiveness; (c) accuracy; (d) appropriateness for the firm’s or fund’s current activities (e) current regulatory requirements; (f) any prior policy issues, violations or sanctions; and (g) any changes or updates that may otherwise be required or appropriate.

Larry E. Hilkemann, or designee(s), will coordinate the review of each policy with an appropriate person, department manager, management person or officer to ensure that each of the firm’s policies and procedures is adequate and appropriate for the business activity covered, e.g., a review of trading policies and procedures with the person responsible for the firm’s trading activities.

Larry E. Hilkemann, or designee(s), will revise or update any of the firm’s policies and/or procedures as necessary or appropriate and obtain the approval of the person, department manager, management person or officer responsible for a particular activity as part of the review.

Larry E. Hilkemann will obtain the approval of the firm’s compliance policies and procedures from the appropriate senior management person or officer, or chief executive officer.

For advisers who also advise investment companies, the investment company’s board of directors/trustees) must review the adviser’s policies and procedures as well as those of service providers. Larry E. Hilkemann will submit a report to the board(s) of the investment company(s) regarding the reviews of the adviser’s and service providers’ policies and procedures on an annual basis regarding the firm’s /funds’ annual review(s).

The firm’s annual reviews will include a review of any prior violations or issues under any of the firm’s policies or procedures with any revisions or amendments to the policy or procedures designed to address such violations or issues to help avoid similar violations or issues in the future.

Larry E. Hilkemann will maintain hardcopy or electronic records of the firm’s policies and procedures as in effect at any particular time since 10/05/2004, and any policies in effect prior to that date;

Larry E. Hilkemann will also maintain an Annual Compliance Review file for each year which will include and reflect any revisions, changes, updates, and materials supporting such changes and approvals, of any of the firm’s policies and/or procedures.

Larry E. Hilkemann, or designee(s), will also conduct more frequent reviews of the Wealth Management LLC's policies or procedures, or any specific policy or procedure, in the event of any change in personnel, business activities, regulatory requirements or developments, or other circumstances requiring a revision or update.

Relevant records of such additional reviews and changes will also be maintained by Larry E. Hilkemann.


1/1/2015 to Current

Anti-Money Laundering

Policy

It is the policy of Wealth Management LLC to seek to prevent the misuse of the funds it manages, as well as preventing the use of its personnel and facilities for the purpose of money laundering and terrorist financing. Wealth Management LLC has adopted and enforces policies, procedures and controls with the objective of detecting and deterring the occurrence of money laundering, terrorist financing and other illegal activity. Anti-money laundering (“AML”) compliance is the responsibility of every employee. Therefore, any employee detecting any suspicious activity is required to immediately report such activity to the AML Compliance Officer. The employee making such report should not discuss the suspicious activity or the report with the client in question.

Background

On October 26, 2001, the President signed into law the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (“USA PATRIOT Act”). Prior to the passage of the USA PATRIOT Act, regulations applying the anti-money laundering provisions of the Bank Secrecy Act (“BSA”) were issued only for banks and certain other institutions that offer bank-like services or that regularly deal in cash. The USA PATRIOT Act required the extension of the anti-money laundering requirements to financial institutions, such as registered and unregistered investment companies, that had not previously been subjected to BSA regulations. In April 2003, the Department of the Treasury proposed new rules that would require SEC registered advisers, and certain unregistered advisers, to adopt an anti-money laundering program.

Responsibility

Wealth Management LLC has designated Larry E. Hilkemann as Wealth Management LLC 's AML Compliance Officer. In this capacity, the AML Compliance Officer is responsible for coordinating and monitoring the firm’s AML program as well as maintaining the firm’s compliance with applicable AML rules and regulations. The AML Compliance Officer will review any reports of suspicious activity, which have been observed and reported by employees.

Procedure


Client Identification Procedures As part of Wealth Management LLC 's AML program, the firm has established procedures to ensure that all clients’ identities have been verified before an account is opened. Before opening an account for an individual client, Wealth Management LLC will require satisfactory documentary evidence of a client’s name, address, date of birth, social security number or, if applicable, tax identification number. Before opening an account for a corporation or other legal entity, Wealth Management LLC will require satisfactory evidence of the entity’s name, address and that the acting principal has been duly authorized to open the account. The AML Compliance Officer will retain records of all documentation that has been relied upon for client identification for a period of five years. Prohibited Clients Wealth Management LLC will not open accounts or accept funds or securities from, or on behalf of, any person or entity whose name appears on the List of Specially Designated Nationals and Blocked Persons maintained by the U.S. Office of Foreign Assets Control, from any Foreign Shell Bank or from any other prohibited persons or entities as may be mandated by applicable law or regulation. Wealth Management LLC will also not accept high-risk clients (with respect to money laundering or terrorist financing) without conducting enhanced, well-documented due diligence regarding such prospective client.

The following is a list of potentially suspicious activities that has been generated by the Financial Industry Regulatory Authority (FINRA). While Wealth Management LLC is not a FINRA member and its advisory activities are not subject to FINRA's jurisdiction, the information provided by the FINRA is a good reference.

The customer exhibits unusual concern about the firm's compliance with government reporting requirements and the firm's anti-money laundering policies (particularly concerning his or her identity, type of business and assets), or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspicious identification or business documents.

The customer wishes to engage in transactions that lack business sense or

apparent investment strategy, or are inconsistent with the client's stated business or investment strategy.

The information provided by the customer that identifies a legitimate source

for funds is false, misleading, or substantially incorrect. Upon request, the customer refuses to identify or fails to indicate any

legitimate source for his or her funds and other assets. The customer (or a person publicly associated with the customer) has a

questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.

The customer exhibits a lack of concern regarding risks and transaction costs.

The customer appears to be acting as an agent for an undisclosed principal,

but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity.

The customer has difficulty describing the nature of his or her business or

lacks general knowledge of his or her industry. The customer attempts to make frequent or large deposits of currency, insists

on dealing only in cash, or asks for exemptions from the firm's policies relating to the deposit of cash.

The customer engages in transactions involving cash or cash equivalents or

other monetary instruments that appear to be structured to avoid the $10,000 government reporting requirements, especially if the cash or monetary instruments are in an amount just below reporting or recording thresholds.

For no apparent reason, the customer has multiple accounts under a single

name or multiple names, with a large number of inter-account or third-party transfers.

The customer is from, or has accounts in, a country identified as a non-

cooperative country or territory by the Financial Action Task Force. The customer's account has unexplained or sudden extensive wire activity,

especially in accounts that had little or no previous activity. The customer's account shows numerous currency or cashiers check

transactions aggregating to significant sums. The customer's account has a large number of wire transfers to unrelated

third parties inconsistent with the customer's legitimate business purpose. The customer's account has wire transfers that have no apparent business

purpose to or from a country identified as money laundering risk or a bank secrecy haven.

The customer's account indicates large or frequent wire transfers,

immediately withdrawn by check or debit card without any apparent business purpose.

The customer makes a funds deposit followed by an immediate request that

the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose.

The customer makes a funds deposit for the purpose of purchasing a long-

term investment followed shortly thereafter by a request to liquidate the position and transfer of the proceeds out of the account.

The customer engages in excessive journal entries between related accounts

without any apparent business purpose. The customer requests that a transaction be processed to avoid the firm's

normal documentation requirements. The customer, for no apparent reason or in conjunction with other red flags,

engages in transactions involving certain types of securities, such as penny

stocks, Regulation S stocks, and bearer bonds, which although legitimate have been used in connection with fraudulent schemes and money laundering activity. (Such transactions may warrant further due diligence to ensure the legitimacy of the customer's activity).

The customer's account shows an unexplained high level of account activity

with very low levels of securities transactions. The customer maintains multiple accounts, or maintains accounts in the

names of family members or corporate entities, for no apparent purpose. The customer's account has inflows of funds or other assets well beyond the

known income or resources of the customer.

Annual Training and Review The AML Compliance Officer will conduct periodic employee training programs for appropriate personnel regarding the AML program as deemed necessary. Such training programs will review applicable laws, regulations and recent trends in money laundering and their relation to Wealth Management LLC's business. Attendance at these programs is mandatory for appropriate personnel, and session and attendance records will be retained for a five-year period.

The AML program will be reviewed annually by the AML Officer, the Chief Compliance Officer or an independent auditor. The review of the AML program will be conducted as part of the firm's annual compliance program review of the policies and procedures. The AML review will also evaluate Wealth Management LLC’s AML program for compliance with current AML laws and regulations.


1/1/2015 to Current

Best Execution

Policy

As an investment advisory firm, Wealth Management LLC has a fiduciary and fundamental duty to seek best execution for client transactions. Wealth Management LLC , as a matter of policy and practice, seeks to obtain best execution for client transactions, i.e., seeking to obtain not necessarily the lowest commission but the best overall qualitative execution in the particular circumstances.

Background

Best execution has been defined by the SEC as the “execution of securities transactions for clients in such a manner that the clients’ total cost or proceeds in each transaction is the most favorable under the circumstances.” The best execution responsibility applies to the circumstances of each particular transaction and an adviser must consider the full range and quality of a broker-dealer’s services, including execution capability, commission rates, the value of any research, financial responsibility and responsiveness, among other things.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our best execution policy, practices, disclosures and recordkeeping.

Procedure


As part of Wealth Management LLC 's brokerage and best execution practices, Wealth Management LLC has adopted and implemented written best execution practices and established a Brokerage Committee (or designated an individual or officer).

The Brokerage Committee (or designated officer) which has responsibility for monitoring our firm’s trading practices, gathering relevant information, periodically reviewing and evaluating the services provided by broker-dealers, the quality of executions, research, commission rates, and overall brokerage relationships, among other things.

Wealth Management LLC also conducts periodic reviews of the firm’s brokerage and best execution practices, evaluates services and documents these reviews, and discloses a summary of brokerage and best execution practices in our Form ADV Part II.

A Best Execution file is maintained for the information obtained and used in Wealth Management LLC 's periodic best execution reviews and analysis and to document the firm’s best execution practices.

As part of the annual review a report will be prepared to document and determine that the best execution duty is being fulfilled.


1/1/2015 to Current

Books and Records

Policy

As a registered investment adviser, Wealth Management LLC is required, and as a matter of policy, maintains various books and records on a current and accurate basis which are subject to periodic regulatory examination. Our firm’s policy is to maintain firm and client files and records in an appropriate, current, accurate and well-organized manner in various areas of the firm depending on the nature of the records. Wealth Management LLC 's policy is to maintain required firm and client records and files in an appropriate office of Wealth Management LLC for the first two years and in a readily accessible facility and location for an additional three years for a total of not less than five years from the end of the applicable fiscal year. Certain records for the firm’s performance, advertising and corporate existence are kept for longer periods.

Background

Registered investment advisers, as regulated entities, are required to maintain specified books and records. There are generally two groups of books and records to be maintained. The first group is financial records for an adviser as an on-going business such as financial journals, balance sheets, bills, etc. The second general group of records are client related files as a fiduciary to the firm’s advisory clients and these include agreements, statements, correspondence and advertising, trade records, among many others.

Responsibility

Joyce Schmidt has the overall responsibility for the implementation and monitoring of our books and records policy, practices, disclosures and recordkeeping for the firm.

Procedure

Wealth Management LLC has adopted procedures to implement the firm’s policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following: Wealth Management LLC 's designated officer, individual, or department manager(s), as may be appropriate, has the responsibility for the firm's filing systems for the books, records and files required to be maintained by Wealth Management LLC . Wealth Management LLC 's filing systems for records, whether stored in files or electronic media, are designed to meet the firm’s policy, business needs and regulatory requirements as follows:

Arranging for easy location, access and retrieval;

Having available the means to provide legible true and complete copies;

For records stored on electronic media, back-up files are made and such records stored separately;

Reasonably safeguarding all files, including electronic media, from loss, alteration or destruction;

Limiting access by authorized persons to Wealth Management LLC 's records and;

Ensuring that any non-electronic records that are electronically reproduced and stored are accurate reproductions.

Periodic reviews may be conducted by the designated officer, individual or department managers to monitor Wealth Management LLC 's recordkeeping systems, controls, and firm and client files.


1/1/2015 to Current

Client Communications and Correspondence

Policy It is the policy of Wealth Management LLC to either document or retain relevant communications and/or correspondence with investment clients. Such documentation is invaluable when questions arise about the communications and correspondence after time and memories wane. Background Client communications are an important part of Wealth Management LLC’s business practices and operations. Communication with clients comes in various forms, which includes advertising, seminars, one-on-one meetings, written correspondence, and verbal correspondence. Rule 206(4)-1 of the Advisers Act governs the use of advertising by the firm and is applicable to much of the firm’s communications with clients. Please see section on Advertising which details what can be included in communications with our clients and what should not be included. Responsibility It is the responsibility of each investment advisor representative and ultimately the Chief Compliance Officer that this policy is being followed. Procedure Wealth Management LLC has adopted various policies to implement the firm’s policy that all relevant communications and correspondence be documented as follows:

Phone conversations, voice mails, and meetings with the client that are relevant to the client’s financial situation must be documented and kept as a permanent record. Electronic programs are available to keep such information on a per client basis.

Emails from clients that are relevant must be documented and kept as a permanent record. Electronic programs are available to keep such information on a per client basis.

Documents and other information prepared for or provided by the client should be scanned, or saved and documented electronically on a per client basis.

Supervised persons not approved as investment advisor representatives are not allowed to provide any recommendations or investment advice, or provide any commentary to a client or potential client that may be construed as providing investment advice.


1/1/2015 to Current

Client Fees

Policy Wealth Management LLC provides investment adviser services on a fee-only basis. These fees are assessed the client in advance on a quarterly basis. If a client decides to not use the investment adviser services of Wealth Management LLC during the quarter, any unearned portion will be refunded to client if it equals or exceeds $50.00. Responsibility The Chief Compliance Officer has overall responsibility for the firm’s policy on client fees. Background The Investment Advisory Agreement which is signed and provided to each client governs how fees are charged the client and the rate charged. It is important that the client is not overcharged. To err in charging the client it is better to undercharge the client than overcharge. However, these procedures are established to ensure the proper billing of the client. Procedures

The investment advisor representative on the client account should sign and have the client sign an Investment Advisory Agreement (IAA) at the time or before adviser services commence. This agreement details the fees to be charged the client for investment adviser services.

The backoffice staff is responsible to enter the appropriate fee rate in to the computerized billing system. The fee rate entered should be the same as agreed upon in the Investment Advisory Agreement (IAA).

The investment advisor representative responsible on the client account will review the billing rate and charges when reviewing the quarterly statements before they are given to the client. At that point the investment advisor representative will also determine that the bill calculations appear correct and are based upon the assets being managed, and determine if there are any positions in the account that are held as an accommodation for the client for which no fees are being charged. If an improper fee charge is found during the review of the quarterly statements, then the reviewer should complete the spreadsheet that has been developed for such reviews and denote the issue thereon for back office staff to make the correction in the charge or rate. These will then be compared to the spreadsheet that is given to the Custodian to deduct fees, so that proper amounts are deducted.

The Chief Compliance Officer and/or designated person(s) will periodically check on a test

basis that the appropriate billings are being assessed the clients. The testing results will be documented. If billing errors are found, then appropriate measures will be taken by the Chief Compliance Officer to develop safeguards and additional procedures to keep it from happening in the future, and staff will be directed to adjust the client’s account, accordingly to reflect the proper billing.


1/1/2015 to Current

Complaints

Policy As a registered adviser, and as a fiduciary to our advisory clients, our firm has adopted this policy, which requires a prompt, thorough and fair review of any advisory client complaint, and a prompt and fair resolution which is documented with appropriate supervisory review.

Background

Based on an adviser's fiduciary duty to its clients and as a good business practice of maintaining strong and long term client relationships, any advisory client complaints of whatever nature and size should be handled in a prompt, thorough and professional manner. Regulatory agencies may also require or request information about the receipt, review and disposition of any written client complaints.

Responsibility

Wealth Management LLC 's designated officer, Larry E. Hilkemann, has the primary responsibility for the implementation and monitoring of the firm's complaint policy, practices and recordkeeping for the firm.

Procedure

Wealth Management LLC has adopted procedures to implement the firm's policy and reviews to monitor and insure the firm's policy is observed, implemented properly and amended or updated as appropriate, which include the following:

Wealth Management LLC maintains a Complaint File for any written complaints received from any advisory clients.

Any person receiving any written client complaint is to forward the client complaint to Wealth Management LLC 's designated officer.

If appropriate, the designated officer will promptly send the client a letter acknowledging receipt of the client's complaint letter indicating the matter is under review and a response will be provided promptly.

The designated officer will forward the client complaint letter to the appropriate person or department, depending on the nature of the complaint, for research, review and information to respond to the client complaint.

The designated officer will then either review and approve or draft a letter to the client responding to the client's complaint and providing background information and a resolution of the client's complaint. Any appropriate supervisory review or approval will be done and noted.

The designated officer will maintain records and supporting information for each written client complaint in the firm's complaint file.

Any complaints that deal with not following the Investment Advisor Agreement or the

Investment Policy Statement need to be forwarded to the Chief Compliance Officer. These types of complaints will be dealt with the investment advisor representative and the client. Action will be taken to resolve any disputes.

Complaints about market fluctuations do not need to be reported upon if the Investment

Policy Statement is being followed.


1/1/2015 to Current

Corporate Records

Policy

As a registered investment adviser and legal entity, Wealth Management LLC has a duty to maintain accurate and current “Organization Documents.” As a matter of policy, Wealth Management LLC maintains all Organization Documents, and related records at its principal office. All Organization Documents are maintained in a well-organized and current manner and reflect current directors, officers, members or partners, as appropriate. Our Organization Documents will be maintained for the life of the firm in a secure manner and location and for an additional three years after the termination of the firm.

Background

Organization Documents, depending on the legal form of an adviser, may include the following, among others:

Articles of Incorporation, By-laws, etc (for corporations) Agreements and/or Articles of Organization (for limited liability companies) Partnership Agreements and/or Articles (for partnerships and limited liability partnerships) Charters Minute Books Stock certificate books/ledgers Organization resolutions Any changes or amendments of the Organization Documents

Responsibility

Nancy Brozek & Joyce Schmidt have the responsibility for the implementation and monitoring of our Organization Documents policy, practices, and recordkeeping.

Procedure

Wealth Management LLC has adopted procedures to implement the firm's policy and reviews to monitor and insure the firm's policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Wealth Management LLC 's designated officer will maintain the Organization Documents in Wealth Management LLC 's principal office in a secure location.

Organization Documents will be maintained on a current and accurate basis and periodically reviewed and updated by the designated officer so as to remain current and accurate with Wealth Management LLC 's regulatory filings, among other things.


1/1/2015 to Current

Custody

Policy

As a matter of policy and practice, Wealth Management LLC does not permit employees or the firm to accept or maintain custody of client assets. It is our policy that we will not accept, hold, directly or indirectly, client funds or securities, or have any authority to obtain possession of them, except for the direct debiting of advisory fees. Wealth Management LLC will not intentionally take custody of client cash or securities, except for advisory fees as previously discussed.

Background

The custody rule under the Investment Advisers Act of 1940 defines custody as "holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them." The custody definition now includes three examples to clarify what constitutes custody for advisers as follows:

1. Possession of client funds or securities, unless an adviser receives them inadvertently e.g., from a client. If the adviser returns them within three business days of receipt, custody can be avoided (inadvertent custody);

2. Any arrangement which authorizes or permits an adviser to withdraw client funds or securities, e.g., a general power of attorney, direct debiting of advisory fees, etc.; and

3. Any capacity, e.g., general partner of a limited partnership, trustee, etc., that gives an adviser, or supervised person, legal ownership or access to client funds or securities.

The custody rule requires advisers with custody to maintain client funds and securities with "qualified custodians," which include banks, registered broker-dealers, and certain foreign custodians, which provide at least quarterly account statements directly to the adviser's clients.

For advisers with custody who do use qualified custodians, the prior requirements of having a surprise annual audit and delivering an audited balance sheet as part of Form ADV Part II have been eliminated except as noted below. For advisers with custody who do not use qualified custodians, they must still send quarterly account statements to clients and undergo an annual surprise examination by an independent public accountant to verify client funds and securities. Any material discrepancies found by the accountant must be reported to the SEC within one day. The requirement to deliver an audited balance sheet with Form ADV Part II has been eliminated for these advisers also. Advisers that deduct fees directly from client accounts will be deemed to have custody and must comply with the requirements of the new rule in lieu of no-action letters issued by SEC staff. However, advisers that have custody only because they deduct fees may continue to answer "no" to the custody questions in Item 9 of Form ADV Part 1.

SEC advisers with custody of client funds or securities or with any client relationships which could cause them to be deemed to have custody, were required to be in compliance with the revised SEC custody rule by April 1, 2004.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our policies, practices, disclosures and recordkeeping to ensure we are not deemed a custodian. In the event any employee of Wealth Management LLC receives funds, securities, or other assets from a client, such employee must immediately notify the Compliance Officer and arrange to return such funds, securities or other assets to the client within three business days of receiving them.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm’s policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate which include the following:

Securities and funds of custodial clients are maintained with a qualified custodian or, in the case of accounts holding shares of open-end mutual funds, the fund's transfer agent and held in the client's name or under Wealth Management LLC as agent or trustee for the clients;

Wealth Management LLC has a reasonable belief that the qualified custodian(s) holding

client assets provides at least quarterly account statements directly to those client or an "independent representative" of their choosing that does not have a "control" relationship within the past two years with Wealth Management LLC;

If Wealth Management LLC receives inadvertently from a client any funds or securities,

these assets shall be returned to the client as soon as reasonably possible. Stock certificates should remain with the client at all times. Employees can help client prepare certificates for mailing, but client must be responsible for mailing.

No employee or supervised person of Wealth Management LLC shall knowingly accept

actual possession of any client funds or securities. Persons receiving a request from a client to deposit assets with a qualified custodian may assist the client to complete necessary forms and/or mailings, but shall not take actual possession of the funds or securities. Likewise, persons receiving requests to withdraw assets with a qualified custodian may assist the client to complete the transaction, but must have the client sign either the custodian's paperwork for such request or the Withdrawal Request and Receipt Form and maintain a copy in the client file.

Wealth Management LLC, may receive checks that are made payable to a third party

custodian and then can forward them to the custodian for deposit in the client's account. Wealth Management LLC should never receive a check made payable to Wealth Management LLC for deposit in the client's account and must return any check received in this manner to the client.

To avoid being deemed to have custody, Wealth Management LLC’s procedures prohibit the following practices:

Any employee, officer, and/or the firm from having signatory power over any client’s checking account; Any employee, officer, and/or the firm from having the power to unilaterally wire funds from a client’s account; Any employee, officer, and/or the firm from holding any client’s securities or funds in Wealth Management LLC’s name at any financial institution; Any employee, officer, and/or the firm from physically holding cash or securities of any client; Any employee, officer, and/or the firm from having general power of attorney over a client’s account; Any employee, officer, and/or the firm from holding client assets through an affiliate of Wealth Management LLC where the firm, its employees or officers have access to advisory client assets; Any employee, officer, and/or the firm from receiving the proceeds from the sale of client securities or interest or dividend payments made on a client’s securities or check payable to the firm except for advisory fees; Any employee, officer and/or the firm from acting as a trustee or executor for any advisory client trust or estate; and Any employee, officer and/or the firm from acting as general partner and investment adviser to any investment partnership.

Wealth Management LLC allows for the exclusion of this policy in the

following circumstances:

Any employee, officer, and/or the firm directly deducting advisory fees from a client’s account;

Any employee, officer, and/or the firm acting as a trustee or executor for any advisory client trust or estate for a family member or for a client for which a relationship was in place prior to becoming an investment client,

Any employee acting as a general power of attorney for a family member or for a client for which a relationship was in place prior to becoming an investment client.


1/1/2015 to Current

Directed Brokerage

Policy Wealth Management LLC 's policy and practice is to not accept advisory clients' instructions for directing a client’s brokerage transactions to a particular broker-dealer.

Background

Clients may direct advisers to use a particular broker-dealer under various circumstances, including where a client has a pre-existing relationship with the broker or participates in a commission recapture program, among other situations. Advisers may also elect not to exercise brokerage discretion and, therefore, require clients to direct brokerage. Advisers should recommend to clients the use of broker-dealers providing reasonable, competitive and quality brokerage services and advise clients if a client's directed broker does not provide competitive and quality services.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our directed brokerage policy that the firm does not accept client instructions for directing brokerage to a particular broker-dealer.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm's policy and reviews to monitor and insure the firm's policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Wealth Management LLC 's policy of prohibiting the acceptance of client instruction for the direction of brokerage has been communicated to relevant individuals including management, traders, and portfolio managers, among others.

The firm's advisory agreements and Disclosure Brochures (Form ADV Part II) disclose the firm's policy of not accepting client directed brokerage instructions.

Larry E. Hilkemann periodically monitors the firm's advisory services and trading practices to help insure no directed brokerage instructions exist or are accepted by the firm.

In the event of any change in the firm's policy, any such change must be approved by management, and any directed brokerage instructions would only be allowed after appropriate reviews and approvals, received in writing, with appropriate disclosures made, regulatory requirements met and proper records maintained.


1/1/2015 to Current

Disaster Recovery

Policy

As part of its fiduciary duty to its clients and as a matter of best business practices, Wealth Management LLC, has adopted policies and procedures for disaster recovery and for continuing Wealth Management LLC’s business in the event of an emergency or a disaster. These policies are designed to allow Wealth Management LLC to resume providing service to its clients in as short a period of time as possible. These policies are, to the extent practicable, designed to address those specific types of disasters that Wealth Management LLC might reasonably face given its business and location.

Background

Since the terrorist activities of 9/11/2001, all advisory firms need to establish written disaster recovery and business continuity plans for the firm’s business. This will allow advisers to meet their responsibilities to clients as a fiduciary in managing client assets, among other things. It also allows a firm to meet its regulatory requirements in the event of any kind of an emergency or disaster, such as a bombing, fire, flood, earthquake, power failure or any other event that may disable the firm or prevent access to our office(s).

Responsibility

Joyce Schmidt is responsible for maintaining and implementing Wealth Management LLC’s Disaster Recovery and Business Continuity Plan.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm’s policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

The following individuals have the primary responsibility for implementation and monitoring of our Disaster Recovery Policy:

Joyce Schmidt is responsible for documenting computer back-up procedures, i.e., frequency, procedure, person(s) responsible, etc.

Joyce Schmidt is responsible for designating back-up storage locations(s) and persons responsible to maintain back-up data in separate locations.

Joyce Schmidt is responsible for identifying and listing key or mission critical people in the event of an emergency or disaster, obtaining their names, addresses, e-mail, fax, cell phone and other information and distributing this information to all personnel.

Joyce Schmidt is responsible for designating and arranging for “hot,” “warm,” or home site recovery location(s) for mission critical persons to meet to continue business, and for obtaining or arranging for adequate systems equipment for these locations.

Joyce Schmidt is responsible for establishing back-up telephone/communication system for clients, personnel and others to contact the firm and for the firm to contact clients.

Joyce Schmidt is responsible for determining and assessing back-up systems for key vendors and mission critical service providers.

Joyce Schmidt is responsible for conducting periodic and actual testing and training for mission critical and all personnel.

Wealth Management LLC’s disaster recovery systems will be tested periodically.

Wealth Management LLC’s Disaster Recovery Plan will be reviewed periodically, and on at least an annual basis, by Joyce Schmidt.

DISASTER RECOVERY INFORMATION CONTACT PERSONNEL: *Creative Solutions: Payroll & Client Writeup - 1-800-968-0600 #130675 *Connecting Point: Primary Contact: James Mortimer 402-371-4530 / 402-844-2310 Direct Please send all support requests (Including Emergency & Afterhours) to: [email protected] -Computer workstations, Servers, and Network Switches & Connectivity Hardware Support -Software:Microsoft Operating System, Microsoft Office, and General PC Application Support -Provides Primary Internet Service to CBF & RPC as well as the McMill Building tenants -Email Account Setup & Maintenance -Printer Maintenance -VoIP Phone System & Service for Retirement Plan Consultants (RPC). *Kooi Communications: 402-371-8757 Phone hardware *Orbitcom: 1-605-977-6900 DSL, FAX and CBF phone service *Western Office Products Plus: 1-402-371-2108 copiers *Franco Postalia: 1-402-371-2108 Postage Meter- (Western Office Products Plus) *PROFX: 1-800-739-9998 Customer # 134503 – Tax software, engagement, etc *Portfolio Center: 1-800-528-9595 maint. code 4844 *TDAmeritrade: 1-800-435-3500 *Prairie Mechanical: A/C and heating repairs for the building - 1-402-331-4050 Pat Kealy *Connecting Point - Printer maintenance is also handled by Keith Harmon Contact - Server & Workstation Maintenance - Clint Bowland *Smarsh - Email and social media archiving, etc. – Mary Kleffner (Account Rep.) 1-971-270-4425 Employee contacts: Home Cell Phone Joyce Schmidt 402-371-2462 402-841-0957 Nancy Brozek 402-841-1458 Jared Faltys 402-371-7937 402-649-4687 Backup Procedures: We run a rotating backup system of four tapes, with a daily backup tape Monday, Tuesday, Wednesday, and Thursday. The Friday tapes are rotated based on the week of the month, 1st Friday, 2nd Friday, 3rd Friday, 4th Friday, and 5th Friday. The last day of the month, this backup is taken off site (to Jared’s house) and kept indefinitely. Backup tapes are kept in the investment vault on-site. The backup process is automated. Any files located directly on a specific workstation Do Not get backed up. Daily, Monday through Friday, the system starts backing up at 6:00 p.m. (CBFSBS2011 Server), at 10:00 p.m. (CBFServer), at 01:00 a.m. (CBFProFX), and at 04:00 a.m. (CBFPortfolio). No data is stored on (Terminal Server), thus it is not in the backup schedule. The critical ones are the Portfolio and ProFX database servers as staff usage during the CBFSBS2011 Server and CBFServer backup has little effect.

VIRUS PROTECTION: We currently use BitDefender Security Manager Antivirus managed by Connecting Point. All updates and scanning are controlled from their web console. Equipment: CBFServer – Current F: Drive Server (Future QB Server), Faxing Server CBFSBS2011 – User Data Storage, Active Directory (Future F: Drive Data Server) CBFProFX - Engagement Server – Server 2012 (vmware) CBFPortfolio - Portfolio Center Server– Server 2012 (vmware), SQL 2008 Terminal Server - Windows Server 2008 R2, Runs Server Backups All servers are located in the “server room” against the North wall. (the black server rack). Connecting Point is responsible for maintaining the functionality of all servers. They have configured the operating system and essential software for running of the system. They also configure and maintain the firewall, switches, VPN hardware, and internet access. All servers are configured with hardware “Raid” protection. In the event 1 drive fails the other drives continue to function to ensure continued server access to the server and data protection. Primary patch panel and switches are located in the main room of the basement of the McMill building on the north wall above the wooden shelves. RPC patch panel is located in the 3rd floor hallway corner closet. Most computer supplies come from Connecting Point. Western Office Products Plus is our supplier for copier paper and maintenance on the copiers. DESIGNATED SITE: Designated site to meet: Jared Faltys’ home office, located at 3300 W. Eisenhower Ave., Norfolk, NE 68701


1/1/2015 to Current

Disclosure Document

Policy

Wealth Management LLC , as a matter of policy, complies with relevant regulatory requirements and maintains our Disclosure Document on a current and accurate basis. Our firm's Disclosure Document provides information about the firm’s advisory services, business practices, professionals, policies and any actual and potential conflicts of interest, among other things.

Background

As a registered investment adviser, Wealth Management LLC has a duty to comply with the disclosure document delivery requirements of Rule 204-3(a) under the Advisers Act. An adviser's Disclosure Document may be Form ADV Part 2 or another document containing all of the information required by Form ADV Part 2.

Responsibility

Larry E. Hilkemann has the responsibility for maintaining Wealth Management LLC 's Disclosure Document on a current and accurate basis, making appropriate amendments and filings, ensuring initial delivery of the Disclosure Document to new clients and existing clients as mandated, sending the annual client offer of the Disclosure Document and maintaining all appropriate files.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm’s policy and reviews to monitor and insure the firm’s disclosure document policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

1. Initial Delivery

A representative of Wealth Management LLC will provide a copy of the firm’s current Disclosure Document to each prospective client either before or at the time of entering into an advisory agreement with a client.

Wealth Management LLC will maintain a document or acknowledgement evidencing delivery of the Disclosure Document to each client.

The Compliance Officer will maintain dated copies of all Wealth Management LLC 's complete Disclosure Documents so as to be able to identify which Disclosure Document was in use at any time.

2. Annual Delivery

Wealth Management LLC will within 120 days after fiscal year-end deliver to existing clients either Form ADV, Part 2A (Firm Brochure) along with a Summary of Material Changes or a Summary of Material Changes accompanied by the website address and an email address and telephone number by which the client may get a copy of the Firm Brochure, and the website address for obtaining information through the IAPD. Form ADV, Part 2A must be updated each year when updating Form ADV (within 90 days of fiscal year-end) through the IARD.

If there are no material changes to the ADV, Part 2A since last updating the amendment, no Firm Brochure or Summary of Material Changes will be delivered to existing clients that year.

ADV, Part 2B (Brochure Supplements must be prepared for supervised persons who either formulate investment advice for clients and have direct client contact, or have discretionary authority over client assets, even if they have no direct client contact.

No Brochure Supplement is required for a supervised person who has no direct client contact and has discretionary authority over client assets only as part of a team. If discretionary advice is provided by a team of more than 5 supervised persons, supplements need only be provided for the 5 supervised persons with the most significant responsibility for the day to day discretionary advice provided.

The Brochure Supplements do not need to be filed with the SEC either on paper or electronically via the IARD system. However, copies must be maintained of all Brochure Supplements and amendments.

Brochure Supplements must be delivered to a client for each supervised person who provides advisory services to that client, except for: those clients who are not required to receive a Firm Brochure, or clients who receive only impersonal investment advice even though they receive a Firm Brochure.

Brochure Supplements must be delivered before or at the time the supervised person begins to provide advisory services to the client.

Brochure Supplements must be updated promptly whenever any information in them becomes materially inaccurate. They are not required to be delivered on particular time intervals after the initial delivery. Updated Brochure Supplements must be delivered to clients if they amend information regarding disciplinary actions.

3. Review and Amendment

The designated officer will review the firm’s complete Disclosure Document on a periodic basis (at least annually) to maintain the Disclosure Document on a current and accurate basis and to properly reflect and be consistent with the firm’s current services, business practices, fees, investment professionals, affiliations and conflicts of interest, among other things.

When changes or updates to the Disclosure Document are necessary or appropriate, the designated officer will make any and all disclosure document amendments timely and promptly and maintain records of the filings and amendments.


1/1/2015 to Current

Discretionary Authority

Policy Through its investment advisory (asset management) services and upon receiving written authorization from a client, Wealth Management LLC maintains trading authorization over client accounts. Upon receiving written authorization from the client, Wealth Management LLC may implement trades on a discretionary basis. When discretionary authority is granted, Wealth Management LLC will have the authority to determine the type of securities and the amount of securities that can be bought or sold for the client’s portfolio without obtaining the client’s consent for each transaction. Wealth Management LLC will maintain the asset allocation selected with the client and provided in the client’s Investment Policy Statement to the best of our ability with expected variances in market fluctuation. Most clients who have contracted for our asset management advisory services are required to grant us discretionary trading authority. Wealth Management LLC does not provide asset management services on a non-discretionary basis except for a few backoffice Registered Investment Advisors who obtain client consent before giving Wealth Management LLC the trades to be made. Wealth Management LLC prepares the proper reports to aide the Registered Investment Advisor and his/her client in making a decision on the trades to be processed. All clients have the ability to place reasonable restrictions on the types of investments that may be purchased in an account. Clients may also place reasonable limitations on the discretionary power granted to our firm so long as the limitations are specifically set forth or included as an attachment to the client agreement. Background It is of the utmost importance that Wealth Management LLC is not construed to have custody of its clients’ assets. Therefore, as described in the policy above the client only gives Wealth Management LLC a limited power of attorney to execute trades without the client’s consent on each transaction. However, one backoffice Registered Investment Advisor does obtain client consent before giving Wealth Management LLC the trades to be made. Responsibility The Chief Compliance Officer is responsible to see that this policy regarding discretionary authority is carried out. Procedures Wealth Management LLC will obtain discretionary authority in the following manner:

When setting up a new account for a client a form granting a limited power of attorney (LPOA) will be completed by Wealth Management LLC’s staff and submitted to the client for signature. This authorization then grants Wealth Management LLC the limited authority to determine the type and amount of securities that can be bought or sold for the client’s portfolio without receiving consent from the client for each transaction. This

discretionary authority is granted to Wealth Management LLC on an account-by-account basis.

Any reasonable restrictions on types of investments that may be purchased in an account

for the client are needed to be documented in the Investment Advisory Agreement (IAA). As noted in the Policy above Wealth Management LLC does provide non-discretionary

services to a few backoffice Registered Investment Advisor clients. These Registered Investment Advisors obtain client consent before giving Wealth Management LLC the trades to be made. Wealth Management LLC prepares the proper reports to aide the Registered Investment Advisor and his/her client in making a decision on the trades to be processed. The clients of these Registered Investment Advisors grant trading authority to Wealth Management LLC through the signing of a limited power of attorney (LPOA).


1/1/2015 to Current

E-Mail and Other Electronic Communications

Policy Wealth Management LLC 's policy provides that e-mail, instant messaging, and other electronic communications are treated as written communications and that such communications must always be of a professional nature. Our policy covers electronic communications for the firm, to or from our clients, and includes any personal e-mail communications within the firm. Personal use of the firm’s e-mail and any other electronic systems is strongly discouraged. Also, all firm and client related electronic communications must be on the firm’s systems, and use of personal e-mail addresses, personal local media, or other personal electronic communications for firm or client communications is prohibited. The use of social media is prohibited until an archiving system is installed and working.

Background

As a result of recent financial industry issues and several regulatory actions against major firms involving very significant fines, financial industry regulators, e.g., SEC and NASD are focusing attention on advisers and broker-dealer policies and practices on the use of e-mail, other electronic communications and retention practices.

The Books and Records rule (Rule 204-2(a)(7)) provides that specific written communications must be kept including those relating to a) investment recommendations or advice given or proposed; b) receipt or delivery of funds or securities; and c) placing and execution of orders for the purchase or sale of securities.

All electronic communications are viewed as written communications, and the SEC has publicly indicated its expectation that firms retain all electronic communications for the required record retention periods. If a method of communication lacks a retention method, then it must be prohibited from use by the firm. Further, SEC regulators also will request and expect all electronic communications of supervised persons to be monitored and maintained for the same required periods. E-mails consisting of spam or viruses are not required to be maintained.

Responsibility

Each employee has an initial responsibility to be familiar with and follow the firm’s e-mail policy with respect to their individual e-mail communications. Larry E. Hilkemann has the overall responsibility for making sure all employees are familiar with the firm’s e-mail policy and social media, implementing and monitoring our e-mail, and social media policy, practices and recordkeeping. Joyce Schmidt is responsible to make sure that the systems are in place and working.

Procedure

Wealth Management LLC has adopted procedures to implement the firm’s policy and reviews to monitor and insure that the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Our firm’s e-mail policy and social media has been communicated to all persons within the firm and any changes in our policy will be promptly communicated.

E-mails and any other electronic communications relating to the firm’s advisory services and client relationships will be maintained and monitored by Joyce Schmidt, Larry E. Hilkemann, or designated person(s) on an on-going or periodic basis through appropriate software programming or sampling of e-mail and social media, as the firm deems most appropriate based on the size and nature of our firm and our business.

Electronic communications records will be maintained and arranged for easy access and retrieval so as to provide true and complete copies with appropriate backup and separate storage for the required periods.

Electronic communications will be maintained in electronic media, with printed copies if appropriate, for a period of two years on-site at our offices and at an off-site location for an additional three years.

The Chief Compliance Officer is responsible with assistance of person(s) designated as follows:

To review any social media site that an associated person intends to use for a business purpose, and it must be reviewed in the form in which it will be "launched".

Participating in an interactive forum is considered a "public appearance" and does not require prior approval; however, such participation must be reviewed after the fact to make sure that such communication does not violate SEC rules.

"Static posts" such as blogs or other writing on web pages are considered as "advertisements" and must be approved prior to being posted.

Data feeds into a website need to be regularly reviewed and any inaccurate information must be corrected.

The regular use pertaining to business of personal devices such as a laptop or smart phone is prohibited. Records of such use must be maintained if used on a regular basis. Copies of any limited use should be submitted to the Chief Compliance Officer for review.

Associated persons may not sponsor or use a communication device that includes technology that automatically erases content.

Training and education concerning social media and other electronic communications will be conducted. "Red flags" that indicate noncompliance must be dealt with appropriately.

A firm that co-brands any part of a third-party site, such as by placing the firm's logo prominently on the site, is responsible for the content of the site. The firm is considered to have adopted the content on that site.

A firm that links to another site is not responsible for the content at that site as long as the firm does not "adopt" or become "entangled" with the content there and does not know or has no reason to know that the site contains false or misleading information.

Wealth Management LLC acknowledges that social media websites are considered to be a form of advertising. No social media accounts can contain the publication or posting of any client testimonials. A third-party's use of the "Like" feature on a registered investment advisor's social media web page could be deemed to be a testimonial if it is an explicit or implicit statement of a client or client's experience with a registered investment advisor or an investment advisor representative. Consequently, the "Like" feature on a registered investment advisor's or investment advisor representative's social media web page is required to be disabled (shut off).

Supervised persons of Wealth Management LLC will not use social media to make any untrue statements or any statements that are otherwise false or misleading.

Supervised persons of Wealth Management LLC are prohibited from using social media for inappropriate purposes. This includes prohibitions against posting copyrighted or offensive material, or using social media to defame or slander others.

All client information will be kept confidential and will not be shared via any social media websites.

Wealth Management LLC uses the archiving service, Smarsh, to supervise social networking sites and document client communication.

When a supervised person is no longer associated with Wealth Management LLC, they will cease using social media to interact with Wealth Management LLC's clients.

All supervised persons must obtain approval from the Chief Compliance Officer prior to using social media to communicate with clients or for any business purposes.

Wealth Management LLC

IA Policies and Procedures Manual 1/1/2015 to Current

ERISA

Policy

Wealth Management LLC may act as an investment manager for advisory clients which are governed by the Employment Retirement Income Security Act (ERISA). As an investment manager and a fiduciary with special responsibilities under ERISA, and as a matter of policy, Wealth Management LLC is responsible for acting solely in the interests of the plan participants and beneficiaries. Wealth Management LLC 's policy includes managing client assets consistent with the “prudent man rule,” maintaining any ERISA bonding that may be required, and obtaining written investment guidelines/policy statements, as appropriate.

Background

ERISA imposes duties on investment advisers that may exceed the scope of an adviser’s duties to its other clients. For example, ERISA specifically prohibits certain types of transactions with ERISA plan clients that are permissible (with appropriate disclosure) for other types of clients. Under Department of Labor guidelines, when the authority to manage plan assets has been delegated to an investment manager, only the manager has the authority to vote proxies, unless a named fiduciary has retained or designated another fiduciary with authority to vote proxies. In certain instances, the Internal Revenue Code may impose requirements on non-ERISA retirement accounts that may mirror ERISA requirements.

In March 2006, the DOL issued new guidance for employers, including advisers, to file annual reports (LM-10) to disclose financial dealings, including gifts and entertainment, with representatives of a union subject to a $250 de minimis fiscal years for 2005 & 2006.

Union Officers and employees have a comparable reporting obligation (Form LM30) to report any financial dealings with employers, including the receipt of any gifts or entertainment above the de minimis amount.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our ERISA policy, practices, disclosures and recordkeeping.

Plan sponsors have proxy voting authority and are responsible to vote proxies.

Procedure


On-going awareness and periodic reviews of a client’s investments and portfolio for consistency with the “prudent man rule.”

On-going awareness and periodic review of any client’s written investment policy statement/guidelines so as to be current and reflect a client’s objectives and guidelines.

Maintain and renew on a periodic basis any ERISA bonding that may be required.

Monitor for and make any annual DOL filings (from LM-10) for reporting financial dealings with union representatives.


1/1/2015 to Current

Fiduciary Duty

Policy Wealth Management LLC recognizes that under the Advisers Act that an investment advisor has a fiduciary duty to its advisory clients. Therefore, Wealth Management LLC is obligated to treat all clients fairly, place the interests of clients first, maintain the confidentiality of client information, have a reasonable, independent basis for investment advice, provide only investment advice that is suitable to each individual client’s needs, goals, and objectives, and personal circumstances, exercise reasonable care to avoid misleading clients, be loyal to the client and act in good faith, obtain best execution when implementing the client’s transactions, and make full and fair disclosure to the client of all material facts and when a conflict of interest or potential conflict exists. Background Section 206 of the Advisers Act states that it is unlawful for a registered investment advisor or investment advisor representative to use the mails or any means or instrumentality of interstate commerce to employ any device, scheme or artifice to defraud a client or prospective client, to engage in any transaction, practice or course of business which defrauds or deceives a client or prospective client, or to engage in fraudulent deceptive or manipulative practices. Responsibility Each investment advisor representative is responsible to see that his or her fiduciary duty to the client is being fulfilled, but ultimately it is the responsibility of the Chief Compliance Officer to monitor that the client’s interests are being placed first even to the detriment of Wealth Management LLC. Procedure Wealth Management LLC has adopted procedures to implement the firm’s policy and to insure that the firm’s policy is being observed and includes the following:

All supervised persons will make full and fair disclosure to clients when a conflict of interest exists.

Disclosures will be provided in Wealth Management LLC’s Form ADV. The Form ADV has been prepared to meet regulatory requirements and to fully inform clients of any situation that may represent a potential conflict of interest.

Investment advisor representatives are required to provide all clients with the firm’s Form ADV, Part 2A , Part 2A Appendix 1 (if applicable) and the Part 2B Brochure Supplement(s) prior to advisory services being provided or at the time of contracting for advisory services with Wealth Management LLC.

All supervised persons will not engage in any fraudulent or deceptive practices in regards to any existing or prospective client for which advisory services may be performed.

All client information will be treated with the highest level of confidentiality.

Wealth Management LLC and its supervised persons will not under any circumstances disclose confidential information to any third party that has not been granted a legal right by the client to receive such information.

Wealth Management LLC will provide all clients a copy of its written Privacy Notice at the time of contracting for advisory services and annually thereafter.


1/1/2015 to Current

Foreign Client Accounts

Policy Wealth Management LLC prohibits the receipt of foreign client accounts unless related to an existing investment adviser client who is not foreign. Any foreign client accounts would have to meet specifications made by the Custodian used before accepted. Due to the complexity and additional liability associated with accepting a foreign client, it is the policy of Wealth Management LLC to not accept a client living outside the United States unless the client has a designated representative (i.e., proxy) living within the United States. Wealth Management LLC is not registered to conduct business with any foreign regulatory authorities. Responsibility The Chief Compliance Officer is responsible to see that investment advisor representatives are aware of this policy and that it is being followed. Procedures Wealth Management LLC has adopted various procedures to ensure that the policy is being followed:

Investment Advisor Representative responsible for the account must determine that a relationship exists to an already existing non-foreign client (such as marriage, child, etc.).

Specifications by the Custodian must be followed in order to set up any foreign client account. Proper information must be provided to the Custodian for them to determine acceptance.

Procedures dealing with money-laundering must also be followed. Statements or other paperwork should not be sent to a foreign country address. Clients should not be contacted when they are outside the United States. All interactions

should be done within the United States. Account statements from the qualified custodian should not be delivered to a foreign

address of the client. If a foreign client domiciled in the United States or a U.S. citizen client is going to live in

another country for a period of time, all documents should be sent to the client’s U.S. address. The client must also designate a U.S.-based proxy or representative to communicate with on the client’s behalf while the client is living abroad.

Investment Advisor Representatives of Wealth Management LLC should not fly to another country to conduct business, should not call on prospects and clients in another country, and should not market services in another country.


1/1/2015 to Current

Gifts And Entertainment

Policy Wealth Management LLC has adopted the rule prohibiting the receiving or giving of gifts exceeding $100 annually to or from investment advisory clients (excluding family) except for certain exemptions from the $100 annual limit for normal business dealings, including: (1) occasional gifts of meals or tickets to theatrical, sporting, and other entertainment, (2) sponsoring legitimate business functions that are recognized by the IRS as deductible business expenses, and (3) gifts of reminder advertising. However, such gifts must not be so frequent or excessive as to raise a suggestion of unethical conduct. Background Lavish or excessive gifts from an advisory client might indicate some form of impropriety or unethical behavior being required of the registered investment advisor firm, its investment advisor representative, or supervised person thereof. Therefore, limits as described herein are required to be adhered to so that no such impropriety could be construed. Responsibility Larry E. Hilkemann has the ultimate responsibility for insuring that the firm’s policy is followed. Procedures Wealth Management LLC has adopted the following procedures for insuring that the firm’s policy is being followed:

Expense reimbursement must be substantiated and approved before payment is made for business related expenses including meals, etc. This is done by Joyce Schmidt and/or management of the Firm.

Annually and upon hire the Annual and Initial Questionnaire is completed by all “access persons” which includes a question regarding gifts received. These are reviewed by the Chief Compliance Officer.

Gifts received in excess of $100 annually would need to be preapproved by both the Chief Compliance Officer and Firm Management before being accepted by any employee of the Firm except for gifts from family who also happen to be clients of Wealth Management LLC.


1/1/2015 to Current

Identity Theft Prevention (Red Flag Rules)

Policy

It is the policy of Wealth Management LLC to seek to prevent the misuse of the funds it manages, as well as preventing the use of its personnel and facilities for the purpose of identity theft. Wealth Management LLC has adopted and enforces policies, procedures and controls with the objective of detecting and deterring the occurrence of identity theft, and other illegal activity. Identity theft (Red Flag Rules) compliance is the responsibility of every employee. Therefore, any employee detecting any suspicious activity is required to immediately report such activity to the Chief Compliance Officer. The employee making such report should not discuss the suspicious activity or the report with the client in question.

Background

On April 10, 2012, the Securities Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) together released their final regulations referred to as Regulation S-ID which requires certain broker-dealers, investment advisers, investment companies, futures commission merchants and other entities subject to the Commission’s respective enforcement authority to establish programs to address identity theft risks. The regulations, at 17 C.F.R. pts. 162 and 248, are effective on May 20, 2013 with compliance with the regulations required as of November 20, 2013.

By definition covered accounts under these regulations are those even if physically held with a qualified custodian, where an adviser has the authority by power of attorney or otherwise to withdraw money from the client’s account and direct payments to third parties according to the investor client’s instructions. The adviser’s authority to withdraw money from the investor client’s account solely to deduct advisory fees without making payments to third parties does not constitute a covered account. Currently, written instructions and permission are received from the client investor or client representative and forwarded to the qualified custodian on a per transaction basis before any payment is made directly to any third party by the qualified custodian. This is done on a very limited basis and is doubtful that it fits the covered account definition.

Wealth Management LLC is taking a proactive approach to Identity Theft Protection whether or not mandated by regulatory definition.

Responsibility

Wealth Management LLC has designated Larry E. Hilkemann as Wealth Management LLC 's Chief Compliance Officer.

In this capacity, the Chief Compliance Officer is responsible for coordinating and monitoring the firm’s Identity Theft Prevention program as well as maintaining the firm’s compliance with applicable Identity Theft Prevention rules and regulations. The Chief Compliance Officer will review any reports of suspicious activity, which have been observed and reported by employees.

Procedure


Client Identification Procedures As part of Wealth Management LLC 's Identity Theft Prevention program, the firm has established procedures to ensure that all clients’ identities have been verified before an account is opened. Before opening an account for an individual client, Wealth Management LLC will require satisfactory documentary evidence of a client’s name, address, date of birth, social security number or, if applicable, tax identification number. Before opening an account for a corporation or other legal entity, Wealth Management LLC will require satisfactory evidence of the entity’s name, address and that the acting principal has been duly authorized to open the account. The Chief Compliance Officer will retain records of all documentation that has been relied upon for client identification for a period of five years. Prohibited Clients Wealth Management LLC will not open accounts or accept funds or securities from, or on behalf of, any person or entity whose name appears on the List of Specially Designated Nationals and Blocked Persons maintained by the U.S. Office of Foreign Assets Control, from any Foreign Shell Bank or from any other prohibited persons or entities as may be mandated by applicable law or regulation or for which alerts, notifications, or other warnings have been received from consumer reporting service providers, such as fraud detection services. Wealth Management LLC will also not accept high-risk clients (with respect to identity theft) without conducting enhanced, well-documented due diligence regarding such prospective client.

The following is a list of potentially suspicious activities or information:

The customer exhibits unusual concern about the firm's compliance with government reporting requirements and the firm's identity theft prevention policies (particularly concerning his or her identity, type of business and assets), or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspicious identification or business documents, or has a suspicious address change. Documents provided for identification appear to have been altered or forged. The photograph or physical description is not consistent with the appearance of the applicant or customer presenting the identification. Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification.

Other information on the identification is not consistent with readily accessible information that is on file, such as a signature or recent check.

An application appears to have been altered or forged, or gives the

appearance of having been destroyed and reassembled.

Personal identifying information provided is inconsistent when compared against external information sources such as: the address does not match any address in a consumer report, or the Social Security Number (SSN) provided has not been issued, or is listed on the Social Security Administration’s Death Master File, or there is a lack of correlation between the SSN range and the date of birth.

The address on an application is fictitious, a mail drop, or a prison.

The phone number provided is invalid, or associated with a pager or

answering service.

The Social Security Number provided is the same as that submitted by other persons opening an account or by other customers.

The person opening the account or the customer fails to provide all required

personal identifying information on an application or in response to a notification that the application is incomplete.

If challenging questions are used to authenticate information beyond that

which is generally available from a wallet or consumer report cannot be provided by the person opening the account or the customer.

A covered account that has been inactive for a reasonably lengthy period of

time is used (taking into consideration the type of account, the expected pattern of usage, and other relevant factors).

Mail sent to the customer is returned repeatedly as undeliverable although

transactions continue to be conducted in connection with the customer’s covered account.

Wealth Management LLC is notified that the customer is not receiving paper

account statements as requested when setting up the account.

Wealth Management LLC is notified that unauthorized charges or transactions are taking place in connection with a customer’s covered account.

Wealth Management LLC is notified that a customer, a victim of identity theft,

a law enforcement authority, or any other person for which a fraudulent account has been opened for a person engaged in identity theft.

The customer wishes to engage in transactions that lack business sense or

apparent investment strategy, or are inconsistent with the client's stated business or investment strategy.

The information provided by the customer that identifies a legitimate source

for funds is false, misleading, or substantially incorrect. Upon request, the customer refuses to identify or fails to indicate any

legitimate source for his or her funds and other assets.

The customer (or a person publicly associated with the customer) has a

questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.

The customer exhibits a lack of concern regarding risks and transaction costs.

The customer appears to be acting as an agent for an undisclosed principal,

but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity.

The customer has difficulty describing the nature of his or her business or

lacks general knowledge of his or her industry. The customer attempts to make frequent or large deposits of currency, insists

on dealing only in cash, or asks for exemptions from the firm's policies relating to the deposit of cash.

For no apparent reason, the customer has multiple accounts under a single

name or multiple names, with a large number of inter-account or third-party transfers.

The customer is from, or has accounts in, a country identified as a non-

cooperative country or territory by the Financial Action Task Force. The customer's account has unexplained or sudden extensive wire activity,

especially in accounts that had little or no previous activity. The customer's account shows numerous currency or cashiers check

transactions aggregating to significant sums. The customer's account has a large number of wire transfers to unrelated

third parties inconsistent with the customer's legitimate business purpose. The customer's account has wire transfers that have no apparent business

purpose to or from a country identified as money laundering risk or a bank secrecy haven.

The customer's account indicates large or frequent wire transfers,

immediately withdrawn by check or debit card without any apparent business purpose.

The customer makes a funds deposit followed by an immediate request that

the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose.

The customer makes a funds deposit for the purpose of purchasing a long-

term investment followed shortly thereafter by a request to liquidate the position and transfer of the proceeds out of the account.

The customer engages in excessive journal entries between related accounts

without any apparent business purpose. The customer requests that a transaction be processed to avoid the firm's

normal documentation requirements.

The customer, for no apparent reason or in conjunction with other red flags,

engages in transactions involving certain types of securities, such as penny stocks, Regulation S stocks, and bearer bonds, which although legitimate have been used in connection with fraudulent schemes and money laundering activity. (Such transactions may warrant further due diligence to ensure the legitimacy of the customer's activity).

The customer's account shows an unexplained high level of account activity

with very low levels of securities transactions. The customer maintains multiple accounts, or maintains accounts in the

names of family members or corporate entities, for no apparent purpose. The customer's account has inflows of funds or other assets well beyond the

known income or resources of the customer. Responses Appropriate responses to possible identity theft may include the following:

Monitoring a covered account for evidence of identity theft.

Contacting the customer.

Changing any passwords, security codes, or other security devices that permit access to a covered account.

Reopening a covered account with a new account number.

Closing an existing covered account.

Notifying law enforcement.

Determining that no response is warranted under the particular

circumstances.

Annual Training and Review The Chief Compliance Officer will conduct periodic employee training programs for appropriate personnel regarding the Identity Theft Prevention program as deemed necessary. Such training programs will review applicable laws, regulations and recent trends in identity theft and their relation to Wealth Management LLC's business. Attendance at these programs is mandatory for appropriate personnel, and session and attendance records will be retained for a five-year period.

The Identity Theft Prevention program will be reviewed annually by the Chief Compliance Officer. The review of the Identity Theft Prevention program will be conducted as part of the firm's annual compliance program review of the policies and procedures. The Chief Compliance Officer’s review will also evaluate Wealth Management LLC’s Identity Theft Prevention program for compliance with current identity theft laws and regulations.


1/1/2015 to Current

Information Security Plan

Policy Wealth Management LLC has adopted an Information Security Plan to address the administrative, technical, and physical safeguards for the protection of client records and information. The purpose of this information security plan is to ensure the security and confidentiality of client personal information, protect against any anticipated threats or hazards to the security of client information, and protect against the risk of identity theft. Background Pursuant to Rule 30 of Regulation S-P Wealth Management LLC as adopted this security plan. Personal information is considered as a person’s first and last name, or first initial and last name, in combination with their Social Security number, driver’s license number or state issued identification card number, or their financial account number or credit or debit card number. Personal information does not include information that is lawfully obtained from publicly available information, or from federal, state, or local government records that are available to the general public. Responsibility The Chief Compliance Officer and Joyce Schmidt have overall responsibility for the firm’s information security policy. Procedures

Personal client information collected by Wealth Management LLC will be limited to what is reasonably necessary to accomplish business purposes or to satisfy regulations. Further, access to personal client information will be limited to those employees required to know such information.

To protect clients’ personal information strong electronic passwords are utilized that contain alphanumeric combinations and lock the device after several unsuccessful attempts, when disposing of old computers, hard drives, and other storage medium are removed and physically destroyed, and wireless connections are password protected.

Documents are required to be shredded when disposing of physical client files. Employees are required to never share their electronic passwords. All client information transferred or stored on portable electronic devices is password

protected. These include but are not limited to: laptops, tablets, external hard drives, CD-Roms, disks, thumb drives, and smart phones.

Employees are required to utilize and update patches for operating systems, firewalls, and anti-virus and malware software for business computers, and personal electronic devices used for business purposes.

To limit outside access to confidential client information via smart phone, it is suggested that each employee password protect his or her smart phone and set the auto-lock function for the shortest possible time.

To further protect the confidentiality of clients’ personal information, all visitors to Wealth Management LLC’s office is suggested to be in the presence of an employee of the firm at all times.

In the event of termination, an employee must return all records containing any form of client personal information. This includes all information stored on laptops or other portable devices or media and information stored in files, records, workpapers, etc. The terminated employee’s physical and electronic access to personal information of clients will be immediately blocked and the terminated employee will be required to surrender all keys, access codes, etc. that permit access to Wealth Management LLC’s premises or information. In addition, the terminated employee’s remote electronic access to personal information will be disabled and his or her voicemail access, email access, internet access, and passwords will be invalidated.

Joyce Schmidt is in charge of Wealth Management LLC’s information security, and is responsible for training employees, and monitoring the security program and its effectiveness thereof.

Employees should report any suspicious or unauthorized use of client information to Joyce Schmidt or the Chief Compliance Officer. A reasonable investigation will be conducted to determine whether a security breach has occurred and the likelihood of the information being misused.

In the event of a security breach, Wealth Management LLC will assess the breach and identify which systems and types of information that were compromised. The firm will then take steps to contain and control the breach and to prevent further unauthorized access or use of the information. Clients of Wealth Management LLC will be notified of the breach if misuse has occurred or it is reasonably possible that misuse will occur. Also, notice will be provided to the SEC or the proper state securities authority. Any such security breach will be documented including when the breach occurred, the information stolen, and an explanation of the steps take to prevent a reoccurrence of the breach.

Due to purchased security services, computers affected by viruses are immediately taken out of the computer network so that it does not spread further.


1/1/2015 to Current

Insider Trading

Policy

Wealth Management LLC 's policy prohibits any employee from acting upon, misusing or disclosing any material non-public information, known as inside information. Any instances or questions regarding possible inside information must be immediately brought to the attention of the designated officer, Legal/Compliance Officer or senior management, and any violations of the firm’s policy will result in disciplinary action and/or termination.

Background

Various federal and state securities laws and the Advisers Act (Section 204A) require every investment adviser to establish, maintain and enforce written policies and procedures reasonably designed, taking into consideration the nature of such adviser’s business, to prevent the misuse of material, nonpublic information in violation of the Advisers Act or other securities laws by the investment adviser or any person associated with the investment adviser.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of the firm’s Insider Trading Policy, practices, disclosures and recordkeeping.

Procedure

Since Wealth Management LLC does not advise its clients on individual stock selection and only advises its clients on mutual funds and ETF’s selection, we require that all advisor representatives must on a quarterly basis acknowledge their personal investment activities as to the purchase or sale of mutual funds and ETF’s , or acknowledge that they purchased or sold individual stocks for the quarter. If personal transactions have taken place for the quarter in individual stocks, then a disclosure of those transactions needs to be made on a form that shows the date of the transaction, the name of the stock transacted, the number of shares transacted, and the dollar amount of the transaction. These transactions include those of the Advisor, and those of his/her spouse (this includes 401(k) transactions as well). The Compliance Officer or a designated officer reviews these acknowledgements and disclosures on a quarterly basis to make sure that this policy is being followed.

Advisor representatives must report to the Compliance Office all business, financial or personal relationships that may result in access to material, non-public information.

Wealth Management LLC has adopted various procedures to implement the firm’s insider trading policy and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Larry E. Hilkemann reviews representatives regarding personal investment activity for Advisor representatives and Advisor representative-related accounts.

Larry E. Hilkemann provides guidance to Advisor representatives on any possible insider trading situation or question,

Wealth Management LLC 's Insider Trading Policy is reviewed and evaluated on a periodic basis and updated as may be appropriate, and

A designated officer or Compliance Officer prepares a written report to management and/or legal counsel of any possible violation of the firm’s Insider Trading Policy for implementing corrective and/or disciplinary action.

See Code of Ethics Manual for additional information regarding Insider Trading and requirements for Pre-Clearance for participation in IPOs (Initial Public Offerings) and Private and Limited Offerings.


1/1/2015 to Current

Investment Processes

Policy As a registered adviser, and as a fiduciary to our advisory clients, Wealth Management LLC is required, and as a matter of policy, obtains background information as to each client's financial circumstances, investment objectives, investment restrictions and risk tolerance, among many other things, and provides its advisory services consistent with the client's objectives, etc. based on the information provided by each client.

Background

The U.S. Supreme Court has held that Section 206 (Prohibited Activities) of the Investment Adviser Act imposes a fiduciary duty on investment advisers by operation of law (SEC v. Capital Gains Research Bureau, Inc., 1963).

Also, the SEC has indicated that an adviser has a duty, among other things, to ensure that its investment advice is suitable to the client's objectives, needs and circumstances, (SEC No-Action Letter, In re John G. Kinnard and Co., publicly available 11/30/1973).

Every fiduciary has the duty and a responsibility to act in the utmost good faith and in the best interests of the client and to always place the client's interests first and foremost.

As part of this duty, a fiduciary and an adviser with such duties, must eliminate conflicts of interest, whether actual or potential, or make full and fair disclosure of all material facts of any conflicts so a client, or prospective client, may make an informed decision in each particular circumstance.

Responsibility

The firm's investment professionals responsible for the particular client relationship have the primary responsibility for determining and knowing each client's circumstances and managing the client's portfolio consistent with the client's objectives. Wealth Management LLC 's designated officer has the overall responsibility for the implementation and monitoring of our investment processes policy, practices, disclosures and recordkeeping for the firm.

Procedure


Wealth Management LLC obtains substantial background information about each client's financial circumstances, investment objectives, and risk tolerance, among other things, through an in-depth interview and information gathering process which includes client profile or relationship forms.

Advisory clients may also have and provide written investment policy statements or written investment guidelines that the firm reviews, approves, and monitors as part of the firm's investment services, subject to any written revisions or updates received from a client.

Wealth Management LLC provides the firm's Form ADV Part II to all prospective clients which discloses the firm's advisory services, fees, conflicts of interest and portfolio/supervisory reviews and investment reports provided by the firm to clients.

Wealth Management LLC may provide periodic reports to advisory clients which include important information about a client's financial situation, portfolio holdings, values and transactions, among other things. The firm may also provide performance information to advisory clients about the client's performance, which may also include a reference to a relevant market index or benchmark.

Investment professionals may also schedule client meetings on a periodic basis, or request basis, to review a client's portfolio, performance, market conditions, financial circumstances, and investment objectives, among other things, to confirm the firm's investment decisions and services are consistent with the client's objectives and goals. Documentation of such reviews should be made in the client file.

Client relationships and/or portfolios may be reviewed on a more formal basis on a quarterly or other periodic basis by designated supervisors or management personnel.


1/1/2015 to Current

Outside Business Activities

Policy It is the policy of Wealth Management LLC that all supervised persons which includes all access persons should submit in writing a disclosure of outside business activity for all activities conducted with the intent of receiving some form of compensation. Before entering such an activity all supervised persons including access persons should receive prior approval, or upon employment with the Firm should disclose any such activities being conducted at the time. Background NASD Rule 3030 currently requires a registered person to provide notice whenever he or she is employed by or accepts any compensation from any person as a result of any business activity. It prohibits any registered person from being an employee, independent contractor, sole proprietor, officer, director or partner of another person, or being compensated, or having the reasonable expectation of compensation from another person as result of any business activity outside the scope of the relationship with his or her member firm, unless he or she has provided prior written notice to the member. Responsibility The Chief Compliance Officer has the responsibility to see that the disclosures regarding outside business activities are received and reviewed. In the event that a conflict of interest arises or that sales of securities beyond the licensing scope of the Firm is being done by the supervised person, those types of activities will be halted by the Chief Compliance Officer. Procedures In order to accomplish the supervision of all supervised persons in regards to any outside business activities, the Chief Compliance Officer or designated officer will utilize the following procedures:

Annually and initially upon hire, all access persons will be required to submit the Initial and Annual Employee Questionnaire. Question number 4 deals with the outside business activities. If question number 4 is affirmatively answered, the access person is directed to also complete the Outside Business Activity Disclosure Form for each outside business activity.

All access persons are required to submit an outside business activity form before starting any outside business activity or outside employment and receiving approval prior to starting such an activity.

Any outside business activity that is either beyond the scope of the Firm’s licensing or which would cause a conflict of interest will be required to be halted by the Chief Compliance Officer.


1/1/2015 to Current

Performance

Policy Wealth Management LLC , as a matter of policy and practice, does not prepare or distribute any performance history or record relating to the investment performance of the firm or advisory clients in the form of public advertising. Performance information with proper disclosures may be utilized to provide client and prospective client risk/required information, etc. to help in developing portfolios suitable to a specific client or prospective client.

Background An investment adviser's performance information is included as part of a firm's advertising practices which are regulated by the SEC under Section 206 of the Advisers Act, which prohibits adviser from engaging in fraudulent, deceptive, or manipulative activities. The manner in which investment advisers portray themselves and their investment returns to existing and prospective clients is highly regulated. These standards include how performance is presented. SEC Rule 206(4)-1 proscribes various advertising practices of investment advisers as fraudulent, deceptive or manipulative and various SEC no-action letters provide guidelines for performance information.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our performance policy that the firm does not prepare or distribute any performance history for the firm or advisory clients.

Procedure


Wealth Management LLC 's policy of prohibiting the preparation and distribution of performance information has been communicated to relevant individuals including management, marketing/sales, and portfolio managers, among others.

Larry E. Hilkemann periodically monitors the firm's advisory services, marketing/sales materials and other materials to help insure that no performance information is prepared and distributed as advertising or marketing materials to any prospective client or others without proper disclosures and within the firm's policy. Copies of information presented to clients or prospective clients should be offered to the

client or prospective client including disclosures. In the event of any change in the firm's policy, any such change must be approved by

management, and any performance information would only be allowed after appropriate reviews and approvals, disclosures, meeting strict regulatory requirements and maintaining proper records.


1/1/2015 to Current

“Pay-To-Play” – Political Contributions

Policy Effective September 13, 2010, the SEC adopted Rule 206(4)-5 which was designed to prevent investment advisors from seeking to influence government officials’ awards of advisory contracts by making or soliciting political contributions to those officials (“pay-to-play” practices). The rule imposes a two-year “time out”, with certain exceptions, on receiving compensation for providing investment advisory services to a government client after any one of certain specified persons makes a contribution to certain candidates or elected officials, limits the use of placement agents to regulated persons that are subject to either the rule itself or comparable rules governing political contributions, and bans solicitations or “bundling” of contributions to certain candidates or elected officials. Wealth Management LLC has adopted this rule which prohibits the giving of political contributions in order to receive favorable treatment in being awarded contracts to receive compensation for investment advisory services. Political contributions in excess of $150 in the aggregate per election in which the contributor is not entitled to vote or political contributions in excess of $350 in the aggregate per election in which the contributor is entitled to vote are prohibited. Responsibility Larry E. Hilkemann has the ultimate responsibility for insuring that the firm’s policy is being followed. Procedures Wealth Management LLC has adopted the following procedures for insuring that the firm’s policy is being followed:

All political contributions totaling $150 or more annually to any particular political candidate or government official, US, state, or local political parties, and political action committees must be disclosed to the Firm. Information as to if the access person involved is able to vote in the election of the specific candidate involved, the date(s) of the contributions, and if the candidate involved could potentially influence a government or political subdivision to act favorably in awarding any investment advisory contracts to the Firm must be disclosed. Potential investment advisory clients would be disclosed who could be influenced by the political candidate in question. This will be disclosed on the Initial and Annual Employee Questionnaire form.

Any new access person to the Firm must disclose any political contributions totaling $150 or more to any particular political candidate or government official, US state or local political parties, and political action committees which took place in the previous two (2) years prior to being hired by the Firm. This will be done on the Initial and Annual Employee Questionnaire form.

If any investment advisory client has been obtained that would be in violation of this SEC rule, then the Firm will not charge any fees to that advisory client for the two (2) year period mandated by the rule.


1/1/2015 to Current

Code of Ethics Policy Wealth Management LLC, as a matter of policy and practice, and consistent with industry best practices and SEC requirements (SEC Rule 204A-1 under the Advisers Act and Rule 17j-1 under the Investment Company Act, which is applicable if the firm acts as investment adviser to a registered investment company), has adopted a written Code of Ethics covering all supervised persons. Our firm's Code of Ethics requires high standards of business conduct, compliance with federal securities laws, reporting and recordkeeping of personal securities transactions and holdings, reviews and sanctions. The firm's current Code of Ethics, and as amended, is incorporated by reference and made a part of these Policies and Procedures. See firm's Code of Ethics under separate cover.

Background

In July 2004, the SEC adopted an important rule (Rule 204A-1) similar to Rule 17j-1 under the Investment Company Act, requiring SEC advisers to adopt a code of ethics. The new rule was designed to prevent fraud by reinforcing fiduciary principles that govern the conduct of advisory firms and their personnel.

The Code of Ethics rule had an effective date of 8/31/2004 and a compliance date of 2/1/2005. Among other things, the Code of Ethics rule requires the following:

setting a high ethical standard of business conduct reflecting an adviser's fiduciary obligations; compliance with federal securities laws; access persons to periodically report personal securities transactions and holdings, with limited exceptions; prior approval for any IPO or private placement investments by access persons; reporting of violations; delivery and acknowledgement of the Code of Ethics by each supervised person; reviews and sanctions; recordkeeping; and summary Form ADV disclosure.

An investment adviser's Code of Ethics and related policies and procedures represent a strong internal control with supervisory reviews to detect and prevent possible insider trading, conflicts of interest and potential regulatory violations.

Responsibility

Larry E. Hilkemann has the primary responsibility for the preparation, distribution, administration, periodic reviews, monitoring our Code of Ethics, practices, disclosures, sanctions and recordkeeping.

Procedure

Wealth Management LLC, has adopted procedures to implement the firm's policy on personal securities transactions and our Code of Ethics and reviews to monitor and insure the firm's policy is observed, implemented properly and amended, as appropriate, which include the following:

Formal adoption of the firm's Code of Ethics by management.

The Chief Compliance Officer or designated person annually or upon revision distributes the current Code of Ethics to all supervised persons and to all new supervised persons upon hire.

Each supervised person must acknowledge receipt of the firm's Code of Ethics initially upon hire annually and upon revision, and return a signed acknowledgement/certification form to the Chief Compliance Officer or designated person.

The Chief Compliance Officer, with other designated officer(s), annually reviews the firm's Code of Ethics and updates the Code of Ethics as may be appropriate.

The Chief Compliance Officer or designated person periodically reviews access persons' personal transactions/holdings reports.

The Chief Compliance Officer, or his/her designee, retains relevant Code of Ethics records as required, including but not limited to, Codes of Ethics, as amended from time to time, acknowledgement/certification forms, initial and annual holdings reports, quarterly reports of personal securities transactions, violations and sanctions, among others.

The firm provides initial and periodic education about the Code of Ethics, and each person's responsibilities and reporting requirements, under the Code of Ethics.

The firm's Form ADV Part II is amended and periodically reviewed by the Chief Compliance Officer to appropriately disclose a summary of the firm's Code of Ethics.

The Chief Compliance Officer is responsible for receiving and responding to any client requests for the firm's Code of Ethics and maintaining required records.


1/1/2015 to Current

Personal Securities Transactions & Records

Policy

Wealth Management LLC 's policy allows employees to maintain personal securities accounts provided any personal investing by an employee in any accounts in which the employee has a beneficial interest, including any accounts for any immediate family or household members, is consistent with Wealth Management LLC 's fiduciary duty to its clients and consistent with regulatory requirements. Each employee must identify any personal investment accounts and report all reportable transactions and investment activity on at least a quarterly basis to the firm’s Compliance Officer, or other designated officer.

Background

For SEC advisers, the Advisers Act has stringent requirements regarding personal securities and transactions. The SEC adopted a new rule (Rule 204 A-1 NOTE: compliance date 2/1/2005), similar to Rule 17j-1 under the Investment Company Act, requiring SEC advisers to adopt a code of ethics that would require, among other things, setting ethical standards and compliance with the securities laws, safeguarding material nonpublic information about clients' transactions and portfolio holdings, initial and annual reports of securities holdings for access persons, and Form ADV Part II summary disclosure about the adviser's code of ethics. (See Code of Ethics Regulatory Reference Section.)

An investment adviser's policies and procedures covering the personal investments of employees and others represents an internal control and supervisory review to detect and prevent possible inside trading, conflicts of interests and possible regulatory violations.

Rule 204A-1 requirements for personal securities transactions must apply to all "access persons" and their household member.

It defines an "access person" as:

"Access person means:

i. Any of your supervised persons:

a. Who has access to nonpublic information regarding any clients' purchase or sale of securities, or nonpublic information regarding portfolio holdings of any reportable fund, or

b. Who is involved in making securities recommendations to clients, or who has access to such recommendations that are nonpublic.

ii. If providing investment advice is your primary business, all of your directors, officers, and partners are presumed to be access persons."

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our policy on personal securities transactions and activities, practices, disclosures and recordkeeping.

Procedure

Wealth Management LLC has adopted procedures to implement the firm’s policy on personal securities transactions and reviews to monitor and insure the firm’s policy is observed, implemented properly and amended or updated, as appropriate, which include the following:

Larry E. Hilkemann maintains a list of the firm’s advisory representatives which is updated periodically.

Employees are to identify any personal investment accounts and any accounts in which the employee has a beneficial interest, including any accounts for the immediate family and household members, upon hire, annually thereafter and upon opening or closing any account(s). This is disclosed on the Initial and Annual Questionnaire. The Holdings Report is also required annually and upon hire. Both the Initial and Annual Questionnaire and the Annual Holdings Report are to be completed by January 31st of each year or within 30 days of notification by the Chief Compliance Officer. All such reports are to be directed to the Chief Compliance Officer, Information provided must be current and the Holdings Report should not contain information more than 45 days prior to submission.

Employees must report all required information for covered personal securities transactions on a quarterly basis within 30 days of the end of each calendar quarter to the Compliance Officer or other designated officer.

The Compliance Officer, or his designee, maintains appropriate records of the firm's advisory representatives, and reports of personal securities transactions, among other things.

The Compliance Officer will review all employees’ reports of personal securities transactions for compliance with the firm’s policies, including the Insider Trading Policy, regulatory requirements and the firm’s fiduciary duty to its clients, among other things. Violations will be reported to management.

Employees are encouraged to arrange for their personal and related accounts to be sent by their brokerage firm/custodians to the Compliance Officer, or other designated officer.


1/1/2015 to Current

Principal Trading

Policy Wealth Management LLC 's policy and practice is to NOT engage in any principal transactions.

Background

Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. As a fiduciary and under the anti-fraud section of the Advisers Act, principal transactions by advisers are prohibited unless the adviser 1) discloses its principal capacity in writing to the client in the transaction and 2) obtains the client’s consent to each principal transaction before the settlement of the transaction.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our principal trading policy and disclosures that the firm/affiliated firm does not engage in any principal transactions with advisory clients.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm's policy and reviews to monitor and insure the firm's policy is observed, implemented properly, and amended or updated, as appropriate, which include the following:

Wealth Management LLC 's policy of prohibiting any principal trades with advisory clients has been communicated to relevant individuals, including management, traders and portfolio managers, among others.

The firm's policy is appropriately disclosed in the firm's Form ADV/Disclosure Document.

Larry E. Hilkemann periodically monitors the firm's advisory services and trading practices to help insure no principal trades occur for advisory clients.

In the event of any change in the firm's policy, any such change must be approved by management, and any principal transactions would only be allowed after appropriate reviews and approvals, disclosures, meeting strict regulatory requirements and maintaining proper records.


1/1/2015 to Current

Privacy

Policy

As a registered investment adviser, Wealth Management LLC must comply with SEC Regulation S-P (or other applicable regulations), which requires registered advisers to adopt policies and procedures to protect the “nonpublic personal information” of natural person consumers and customers and to disclose to such persons policies and procedures for protecting that information. Nonpublic personal information includes nonpublic “personally identifiable financial information” plus any list, description or grouping of customers that is derived from nonpublic personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by Wealth Management LLC to clients, and data or analyses derived from such nonpublic personal information. Wealth Management LLC must also comply with the California Financial Information Privacy Act (SB1) if the firm does business with California consumers.

Background

The purpose of these privacy policies and procedures is to provide administrative, technical and physical safeguards which assist employees in maintaining the confidentiality of nonpublic personal information collected from the consumers and customers of an investment adviser. All nonpublic information, whether relating to an adviser's current or former clients, is subject to these privacy policies and procedures. Any doubts about the confidentiality of client information must be resolved in favor of confidentiality.

Responsibility

Larry E. Hilkemann is responsible for reviewing, maintaining and enforcing these policies and procedures to ensure meeting Wealth Management LLC 's client privacy goals and objectives while at a minimum ensuring compliance with applicable federal and state laws and regulations. Larry E. Hilkemann may recommend to the President any disciplinary or other action as appropriate. Larry E. Hilkemann is also responsible for distributing these policies and procedures to employees and conducting appropriate employee training to ensure employee adherence to these policies and procedures.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm's policy and reviews to monitor and insure the firm's policy is observed, implemented properly and amended or updated, as appropriate, which include the following: Non-Disclosure of Client Information Wealth Management LLC maintains safeguards to comply with federal and state standards to guard each client's nonpublic personal information. Wealth Management LLC does not share any nonpublic personal information with any nonaffiliated third parties, except in the following circumstances:

As necessary to provide the service that the client has requested or authorized, or to maintain and service the client's account;

As required by regulatory authorities or law enforcement officials who have jurisdiction over Wealth Management LLC , or as otherwise required by any applicable law; and

To the extent reasonably necessary to prevent fraud and unauthorized transactions.

Employees are prohibited, either during or after termination of their employment, from disclosing nonpublic personal information to any person or entity outside Wealth Management LLC , including family members, except under the circumstances described above. An employee is permitted to disclose nonpublic personal information only to such other employees who need to have access to such information to deliver our services to the client. Safeguarding and Disposal of Client Information Wealth Management LLC restricts access to nonpublic personal information to those employees who need to know such information to provide services to our clients. Any employee who is authorized to have access to nonpublic personal information is required to keep such information in a secure compartment or receptacle on a daily basis as of the close of business each day. All electronic or computer files containing such information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving nonpublic personal information, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.

Safeguarding standards encompass all aspects of the Wealth Management LLC, that affect security. This includes not just computer security standards but also such areas as physical security and personnel procedures. Examples of important safeguarding standards that Wealth Management LLC, may adopt include:

Access controls on customer information systems, including controls to authenticate and permit access only to authorized individuals and controls to prevent employees from providing customer information to unauthorized individuals who may seek to obtain this information through fraudulent means

(e.g. requiring employee use of user ID numbers and passwords, etc.);

Access restrictions at physical locations containing customer information, such as buildings, computer facilities, and records storage facilities to permit access only to authorized individuals (e.g. intruder detection devices, use of fire and burglar resistant storage devices);

Firewalls and/or password protection of electronic customer information, including while in

transit or in storage on networks or systems to which unauthorized individuals may have access;

Procedures designed to ensure that customer information system modifications are

consistent with the firm's information security program(e.g. independent approval and periodic audits of system modifications);

Dual control procedures, segregation of duties, and employee reference checks for

employees with responsibilities for or access to customer information (e.g. require data entry to be reviewed for accuracy by personnel not involved in its preparation; adjustments and correction of master records should be reviewed and approved by personnel other than those approving routine transactions, etc.);

Monitoring systems and procedures to detect actual and attempted attacks on or

intrusions into customer information systems (e.g. data should be auditable for detection of loss and accidental and intentional manipulation);

Response programs that specify actions to be taken when the firm suspects or detects

that unauthorized individuals have gained access to customer information systems, including appropriate reports to regulatory and law enforcement agencies;

Measures to protect against destruction, loss, or damage of customer

information due to potential environmental hazards, such as fire and water damage or technological failures (e.g. use of fire resistant storage facilities and vaults; backup and store off site key data to ensure proper recovery); and

Information systems security should incorporate system audits and monitoring, security of physical facilities and personnel, the use of commercial or in-house services (such as networking services), and contingency planning.

Any employee who is authorized to possess "consumer report information" for a business purpose is required to take reasonable measures to protect against unauthorized access to or use of the information in connection with its disposal. There are several components to establishing 'reasonable' measures that are appropriate for the firm:

Assessing the sensitivity of the consumer report information we collect;

The nature of our advisory services and the size of our operation;

Evaluating the costs and benefits of different disposal methods; and

Researching relevant technological changes and capabilities.

Some methods of disposal to ensure that the information cannot practicably be read or reconstructed that Wealth Management LLC may adopt include:

Procedures requiring the burning, pulverizing, or shredding or papers containing consumer report information;

Procedures to ensure the destruction or erasure of electronic media; and

After due diligence, contracting with a service provider engaged in the business of record

destruction, to provide such services in a manner consistent with the disposal rule.

Privacy Notices Wealth Management LLC will provide each natural person client with initial notice of the firm's current policy when the client relationship is established. Wealth Management LLC shall also provide each such client with a new notice of the firm’s current privacy policies at least annually. If Wealth Management LLC shares nonpublic personal information relating to a California consumer with an affiliated company under circumstances not covered by an exception under SB1, the firm will deliver to each affected consumer an opportunity to opt out of such information sharing. If, at any time, Wealth Management LLC adopts material changes to its privacy policies, the firm shall provide each such client with a revised notice reflecting the new privacy policies. The Compliance Officer is responsible for ensuring that required notices are distributed to the Wealth Management LLC 's consumers and customers.

A copy of the initial Privacy Notice is kept in each client file with the Investment Advisor Agreement. Annual distribution is included with one of the quarterly cover letters and client quarterly statements. A copy is kept with the cover letter file for the quarter.



Proxy Voting

Policy Wealth Management LLC , as a matter of policy and practice, has no authority to vote proxies on behalf of advisory clients. The firm may offer assistance as to proxy matters upon a client's request, but the client always retains the proxy voting responsibility. Wealth Management LLC 's policy of having no proxy voting responsibility is disclosed to clients.

Background

Proxy voting is an important right of shareholders and reasonable care and diligence must be undertaken to ensure that such rights are properly and timely exercised. Investment advisers registered with the SEC, and which exercise voting authority with respect to client securities, are required by Rule 206(4)-6 of the Advisers Act to (a) adopt and implement written policies and procedures that are reasonably designed to ensure that client securities are voted in the best interests of clients, which must include how an adviser addresses material conflicts that may arise between an adviser's interests and those of its clients; (b) to disclose to clients how they may obtain information from the adviser with respect to the voting of proxies for their securities; (c) to describe to clients a summary of its proxy voting policies and procedures and, upon request, furnish a copy to its clients; and (d) maintain certain records relating to the adviser's proxy voting activities when the adviser does have proxy voting authority.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our proxy policy and to ensure that the firm does not accept or exercise any proxy voting authority on behalf of clients without an appropriate review and change of the firm's policy with appropriate regulatory requirements being met and records maintained.

Procedure


Wealth Management LLC discloses its proxy voting policy of not having proxy voting authority in the firm's Disclosure Document or other client information.

Wealth Management LLC 's advisory agreements provide that the firm has no proxy voting responsibilities and that the advisory clients expressly retain such voting authority.

Wealth Management LLC 's new client information materials may also indicate that advisory clients retain proxy voting authority.

Larry E. Hilkemann reviews the nature and extent of advisory services provided by the firm and monitors such services to periodically determine and confirm that client proxies are not being voted by the firm or anyone within the firm.


1/1/2015 to Current

Registration

Policy

As a registered investment adviser, Wealth Management LLC maintains and renews its adviser registration on an annual basis through the Investment Adviser Registration Depository (“IARD”), for the firm, state filings, as appropriate, and investment adviser representatives (“IARs”). Wealth Management LLC 's policy is to monitor and maintain all appropriate firm and IAR registrations that may be required for providing advisory services to our clients in any location. Wealth Management LLC monitors the state residences of our advisory clients, and will not provide advisory services unless appropriately registered as required, or a de minimis or other exemption exists. This is to be done on an on-going as well as a periodic basis.

Background

In accordance with the Advisers Act, and unless otherwise exempt from registration requirements, investment adviser firms are required to be registered either with the Securities and Exchange Commission (SEC) or with the state(s) in which the firm maintains a place of business and/or is otherwise required to register in accordance with each individual state(s) regulations and de minimis requirements. The registered investment adviser is required to maintain such registrations on an annual basis through the timely payment of renewal fees and filing of the firm’s Annual Updating Amendment. Individuals providing advisory services on behalf of the firm are also required to maintain appropriate registration(s) in accordance with each state(s) regulations unless otherwise exempt from such registration requirements. The definition of investment adviser representative may vary on a state-by-state basis. Supervised persons providing advice on behalf of SEC-registered advisers are governed by the federal definition of investment adviser representative to determine whether or not state IAR registration is required. The investment adviser representative registration(s) must also be renewed on an annual basis through the timely payment of renewal fees.

Responsibility

The Chief Compliance Officer and Joyce Schmidt have the responsibility for the implementation and monitoring of our registration policy, practices, disclosures and recordkeeping.

Procedure


The Compliance Officer, or other designated officer, monitors the state residences of our advisory clients, and the firm and/or its IARs will not provide advisory services unless appropriately registered as required, or a de minimis or other exemption exists.

Wealth Management LLC 's Compliance Officer, or other designated officer, monitors the firm's and IAR registration requirements on an on-going as well as a periodic basis.

Registration filings are made on a timely basis and appropriate files and copies of all filings are maintained by the Compliance Officer or other designated officer.

The Chief Compliance Officer and designated parties will ensure that the information included on Form ADV is accurate and current. The Form ADV will be updated, at least annually, (within 90 days of the firm's fiscal year-end) with current information. If at any time information contained within Form ADV becomes materially inaccurate, Wealth Management LLC will promptly (within 30 days) file an amendment.

The Chief Compliance Officer and designated parties will file a copy of the Form ADV Part 2A (and if applicable, the Part 2A Appendix 1) with the proper regulatory authority as required and when necessary. This will be uploaded to regulators using the IARD system.

The Chief Compliance Officer and designated parties will prepare Form ADV Part 2(b) (Brochure Supplement) will be prepared for any supervised person who formulates investment advice for a client and has direct client contact and for any supervised person who has discretionary authority over a client's assets, even if, that supervised person has no direct client contact. ADV Part 2(b) is not required to be filed using IARD system, however, copies must be maintained by the firm and copies must be provided to clients and prospective clients.

All amendments to Form ADV are maintained in the Historical Filing Section of the IARD and can be electronically retrieved.



Regulatory Examinations

Policy It is the policy of Wealth Management LLC to cooperate with regulatory authorities in the conduct of an examination. Examinations may be conducted on an announced or unannounced basis. Wealth Management LLC will provide documents and information in a timely manner in order to facilitate an efficient completion of the examination. Responsibility The Chief Compliance Officer is ultimately responsible to meet with regulators and see that information and documents are furnished to them in a timely manner. The Chief Compliance Officer may require the help of others designated who have knowledge in certain areas or have an expertise. Procedures Wealth Management LLC will cooperate with regulatory authorities in the conduct of an examination in the following manner:

In an announced examination the SEC staff will send the firm a letter notifying the Firm of the examination which would contain a list of information and/or documents to be reviewed as part of the examination. Some may need to be prepared in an electronic format. This information and documents will either be provided to the SEC upon arrival at the Firm’s office or delivered to the SEC’s offices by a specified date or some combination thereof depending upon the SEC’s request.

In an unannounced examination, as soon as the SEC examiners arrive they will provide the Firm with a list of documents and/or information requested and conduct an initial interview which would be with the Chief Compliance Officer. These documents and/or information will be provided in a timely fashion.

Other personnel may be interviewed by the examiners. Information requested by the examiners in the interview should be answered appropriately and completely, but information not relevant should not be discussed, so that the examination is kept on track and finished efficiently.

During an exit interview, the Chief Compliance Officer will meet with the examiners and will discuss any issues that might have arisen during the examination, provide additional relevant information, and discuss any actions to be taken or plans to be taken to address any issues presented by the examiners.

When the examination has been completed, the Firm will be sent a written notification. It generally will take one of two forms: the examination staff may send the Firm a letter indicating that the examination has concluded without any findings (referred to as a “no-further action letter”), or the examination staff may send the Firm a letter that describes the issues identified, asking the Firm to undertake corrective actions and provide the

examination staff with a written response outlining those actions (referred to as a “deficiency letter”). The Chief Compliance Office would respond to the examination staff in the case of any deficiency and undertake corrective actions that address any issues. Generally, a response to a deficiency letter will need to be completed within 30 days of the issuance of the letter.

Any corrective actions and or suggestions of merit adopted by the Firm made during the examination will be followed up by the Chief Compliance Officer and/or designated officer to be certain that problems are corrected and improvements being utilized. It is the goal of Wealth Management LLC to be compliant with SEC rules and regulations in an efficient and cost-effective manner.

Wealth Management LLC’s intent is to be proactive with respect to compliance matters. Therefore, the Firm conducts periodic assessments of its compliance programs, and may contract with outside parties to perform annual review services, etc. on an as needed basis. All supervised persons are expected to cooperate and participate in any such compliance assessments.



Regulatory Reporting

Policy

As a registered investment adviser with the SEC, or appropriate state(s), Wealth Management LLC 's policy is to maintain the firm’s regulatory reporting requirements on an effective and good standing basis at all times. Wealth Management LLC also monitors, on an on-going and periodic basis, any regulatory filings or other matters that may require amendment or additional filings with the SEC and/or any states for the firm and its associated persons. Any regulatory filings for the firm are to be made promptly and accurately. Our firm’s regulatory filings include Form ADV, Part 1, Form ADV Part 2A, Form ADV, Part 2B, Form 13D, 13F and 13G filings, among others that may be appropriate.

Background

Form ADV, Part 1 may serve as an adviser's Disclosure Document and is an adviser's registration document. Form ADV, therefore, provides information to the public and to regulators regarding an investment adviser. Regulations require that material changes to Form ADV be updated promptly and that Form ADV be updated annually. Form ADV, Part 2A is the adviser's disclosure document in the form of a narrative brochure which contains information about the advisory firm.

Form ADV, Part 2B is the advisor's disclosure document in the form of brochure supplements containing information about certain supervised persons. Forms 13D, 13F and 13G are filings required under the Securities Exchange Act related to client holdings in equity securities.

Responsibility

Larry E. Hilkemann and Joyce Schmidt have the responsibility for the implementation and monitoring of our regulatory reporting policy, practices, disclosures and recordkeeping.

Procedure


Wealth Management LLC makes an annual filing of Form ADV Part 1 and Part 2A within 90 days of the end of each fiscal year (Annual Updating Amendment) to update certain

information required to be updated on an annual basis. These are filed electronically through IARD.

Wealth Management LLC promptly updates our Disclosure Document and certain information in Form ADV, Part 1 and Part 2A when material changes occur.

Form ADV, Part 2B (Brochure Supplements) must be amended promptly if any information in them becomes materially inaccurate. ADV, Part 2B is not filed with the SEC, but a copy must be maintained in the files.

All employees should report to the Compliance Officer, or other designated officer any information in Form ADV and/or the Disclosure Document that such employee believes to be materially inaccurate or omits material information.

Joyce Schmidt will review Forms 13D, 13F and 13G filing requirements and make such filings and keep appropriate records as required. Currently, these forms are not required to be filed.


1/1/2015 to Current

Soft Dollars

Policy Wealth Management LLC , as a matter of policy and practice, does not have any formal or informal arrangements or commitments to utilize research, research-related products and other services obtained from broker-dealers, or third parties, on a soft dollar basis.

Background

Soft dollars generally refers to arrangements whereby a discretionary investment adviser is allowed to pay for and receive research, research-related or execution services from a broker-dealer or third-party provider, in addition to the execution of transactions, in exchange for the brokerage commissions from transactions for client accounts. Section 28(e) of the Securities Exchange Act of 1934 allows and provides a safe harbor for discretionary investment advisers to pay an increased commission, above what another broker-dealer would charge for executing a transaction, for research and brokerage services, provided the adviser has made a good faith determination that the value of the research and brokerage services qualifies as reasonable in relation to the amount of commissions paid. Further, under SEC guidelines, the determination as to whether a product or service is research or other brokerage services, and eligible for the Section 28(e) safe harbor, is whether it provides lawful and appropriate assistance to the investment manager in performance of its investment decision-making responsibilities.

In Interpretative Release Commission Guidance Regarding Client Commission Practices Under Section 28(e), 7/24/2006 the SEC has revised and clarified "brokerage and research services" in view of evolving technologies and industry practices. The Release updates prior Section 28(e) guidance and revises definitions including eligible and non-eligible research products and services for the Section 28(2) safe harbor.

The SEC Release was effective 7/24/2006, and advisers, and market participants, could rely on SEC prior interpretations under Section 28(e) until 1/24/2007 when their soft dollar practices must conform to the new SEC Section 28(e) guidance. (See Regulatory Reference section for additional summary information)

Responsibility Larry E. Hilkemann has the responsibility for the implementation and monitoring of our soft dollar policy that the firm does not utilize any research, research-related products and other services obtained from broker-dealers, or third parties, on a soft dollar basis which results in any additional costs to the client. Therefore, the client cannot be harmed by any such arrangements.

Larry E. Hilkemann has the responsibility to determine that any arrangements that the firm may have to utilize any research, research-related products and other services provided by other firms or organizations with which the firm has a business relationship are not made to the detriment of any client. An appearance of a conflict of interest may exist, but the client’s best interest is the fiduciary responsibility of the firm.

Procedure


Wealth Management LLC 's policy of prohibiting utilizing any research, and research-related products or services has been communicated to relevant individuals including management, traders and portfolio managers, among others. Prohibited arrangements would be those that increase the costs to the client directly.

The firm's policy is appropriately disclosed in the firm's Form ADV Part 2A/Disclosure Document.

Larry E. Hilkemann periodically monitors the firm's business relationships and advisory services to insure no research services or products are being obtained on a soft dollar basis.

In the event of any change in the firm's policy, any such change must be approved by management, and any soft dollar arrangements would only be allowed after appropriate reviews and approvals, disclosures, meeting regulatory requirements and maintaining proper records.


1/1/2015 to Current

Solicitor Arrangements

Policy Wealth Management LLC has adopted procedures for entering into and reviewing solicitor arrangements for making cash payments for the solicitation of clients in accordance with Rule 206(4)-3 of the Advisors Act. Background Under the SEC Cash Solicitation Rule, (Rule 206(4)-3) and comparable rules adopted by most states, investment advisors may compensate persons who solicit advisory clients for a firm if appropriate agreements exist, specific disclosures are made, and other conditions met under the rules. Under the SEC rule, a solicitor is defined as any person who, directly or indirectly, solicits any client for, or refers any client to, an investment advisor. The definition of client includes any prospective client. Responsibility The Chief Compliance Officer has overall responsibility for the firm’s policy on solicitor’s arrangements. Procedures

The solicitor must not have previously committed certain violations outlined in the Advisers Act and must attest to this in the written solicitation agreement.

It must be determined that the solicitor is properly licensed before any arrangement is undertaken. It must be verified that the solicitor and its associates are properly registered as an investment advisor and/or investment advisor representative. A review of applicable state licensing rules as it applies to the solicitor should be completed. Requirements of solicitors may vary from state to state.

The solicitor’s cash fee must be paid pursuant to a written agreement with the advisor of which a copy must be maintained by the advisor, Wealth Management LLC. The agreement describes the solicitation activities, relationship with the advisor, and the compensation to the solicitor.

The solicitor provides only impersonal advisory services and this status and relationship is disclosed to the clients by the solicitor in a specific disclosure which also discloses any increased expenses paid other than the standard advisory fee, if any, by the client to cover a portion of the solicitation fee paid by the advisor to the solicitor.

The solicitor is obligated to comply with the advisor’s policies and procedures, the Advisers Act, and all applicable rules and regulations.

The solicitor must provide the solicited client a copy of Wealth Management LLC’s ADV Part 2A and Part 2B, along with the solicitor’s disclosure document. The solicited client must acknowledge receipt of this information in writing and a copy of this acknowledgement must be provided to the advisor, Wealth Management LLC by the solicitor after this acknowledgement signature is obtained from the client. Only after receipt of this acknowledgement is Wealth Management LLC allowed to proceed with

providing advisory services to the solicited client, and this must be received prior to Wealth Management LLC entering into an investment advisory agreement with the solicited client.

Wealth Management LLC’s designated officer (including the Chief Compliance Officer and designated persons) also periodically review the Form ADV disclosures to insure that the disclosures are accurate and current and consistent with the firm’s policy on paying referral fees for soliciting clients for the firm and these relationships, and arrangements will be reviewed periodically to insure that governing rules and regulations, as well as, the firm’s policy are being followed..


1/1/2015 to Current

Supervision & Internal Controls

Policy

Wealth Management LLC has adopted these written policies and procedures which are designed to set standards and internal controls for the firm, its employees, and its businesses and are also reasonably designed to detect and prevent any violations of regulatory requirements and the firm’s policies and procedures. Every employee and manager is required to be responsible for and monitor those individuals and departments he or she supervises to detect, prevent and report any activities inconsistent with the firm’s procedures, policies, high professional standards, or legal/regulatory requirements.

Background

The SEC adopted a new anti-fraud rule titled Compliance Procedures and Practices (Rule 206(4)-7) under the Advisers Act requiring more formal compliance programs for all SEC registered advisers. The rule became effective 2/5/2004 and SEC advisers had until 10/5/2004 (compliance date) to be in compliance with the new rule.

The recent Compliance Procedures and Practices rule makes it unlawful for a SEC adviser to provide investment advice to clients unless the adviser:

1. adopts and implements written policies and procedures reasonably designed to prevent violations by the firm and its supervised persons;

2. reviews, at least annually, the adequacy and effectiveness of the policies and procedures; 3. designates a chief compliance officer who is responsible for administering the policies and

procedures; and 4. maintains records of the policies and procedures and annual reviews.

Under Section 203(e)(6), the SEC is authorized to take action against an adviser or any associated person who has failed to supervise reasonably in an effort designed to prevent violations of the securities laws, rules and regulations. This section also provides that no person will be deemed to have failed to supervise reasonably provided:

1. there are established procedures and a system which would reasonably be expected to prevent any violations;

2. and such person has reasonably discharged his duties and obligations under the firm's procedures and system without reasonable cause to believe that the procedures and system were not being complied with.

Responsibility

Every employee has a responsibility for knowing and following the firm’s policies and procedures. Every person in a supervisory role is also responsible for those individuals under his/her supervision. The President, or a similarly designated officer, has overall supervisory responsibility for the firm. Larry E. Hilkemann, as the Compliance Officer, has the overall responsibility for monitoring and testing compliance with Wealth Management LLC 's policies and procedures. Possible violations of these policies or procedures will be documented and reported to the appropriate department manager for remedial action. Repeated violations, or violations that the Compliance Officer deems to be of serious nature, will be reported by the Compliance Officer directly to the President, or a similarly designated officer, and/or the Board of Directors.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm’s policy, reviews and internal controls to monitor and insure the firm’s supervision policy is observed, implemented properly and amended or updated, as appropriate which including the following:

Designated a chief compliance officer as responsible for implementing and monitoring the firm's compliance policies and procedures.

Annual compliance training and on-going and targeted compliance training.

Written policies and procedures with statements of policy, designated persons responsible for the policy and procedures designed to implement and monitor the firm's policy.

Annual review of the firm’s policies and procedures by the Compliance Officer and designated persons.

Periodic reviews of employees' activities, e.g., personal trading.

Annual written representations by employees as to understanding and abiding by the firm’s policies.

Supervisory reviews and sanctions for violations of the firm’s policies or regulatory requirements.


1/1/2015 to Current

Trading

Policy

As an adviser and a fiduciary to our clients, our clients’ interests must always be placed first and foremost, and our trading practices and procedures prohibit unfair trading practices and seek to disclose and avoid any actual or potential conflicts of interests or resolve such conflicts in the client’s favor. Our firm has adopted the following policies and practices to meet the firm’s fiduciary responsibilities and to insure our trading practices are fair to all clients and that no client or account is advantaged or disadvantaged over any other. Also, Wealth Management LLC 's trading practices are generally disclosed in our Disclosure Document provided to prospective clients and annually offered to clients.

Background As a fiduciary, many conflicts of interest may arise in the trading activities on behalf of our clients, our firm and our employees, and must be disclosed and resolved in the interests of the clients. In addition, securities laws, insider trading prohibitions and the Advisers Act, and rules thereunder, prohibit certain types of trading activities. Aggregation The aggregation or blocking of client transactions allows an adviser to execute transactions in a more timely, equitable, and efficient manner and seeks to reduce overall commission charges to clients. Our firm’s policy is to aggregate client transactions where possible and when advantageous to clients. In these instances clients participating in any aggregated transactions will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. Currently, there is no advantage to aggregation of client transactions and so it is not being done. Other methodologies, such as Dollar-Cost Averaging are used to minimize trading costs.

In the event transactions for an adviser, its employees or principals (“proprietary accounts”) are aggregated with client transactions, conflicts arise and special policies and procedures must be adopted to disclose and address these conflicts. Allocation As a matter of policy, an adviser's allocation procedures must be fair and equitable to all clients with no particular group or client(s) being favored or disfavored over any other clients.

Wealth Management LLC 's policy prohibits any allocation of trades in a manner that Wealth Management LLC 's proprietary accounts, affiliated accounts, or any particular client(s) or groups of clients receive more favorable treatment than other client accounts. The trading practices of Wealth Management LLC do not lend themselves to preferential treatment of any certain clients. IPOs Initial public offerings (“IPOs”) are offerings of securities which frequently are of limited size and limited availability. IPOs may also become “hot issues” which are offerings that trade at a premium above the initial offering price. In the event Wealth Management LLC participates in any IPOs, Wealth Management LLC 's policy and practice is to allocate IPO shares fairly and equitably among our advisory clients according to a specific and consistent basis so as not to advantage any firm, personal or related account and so as not to favor or disfavor any client, or group of clients, over any other. Currently, Wealth Management LLC does not participate in any Initial Public Offerings (IPOs) or new issues and makes a practice of not doing so. Trade Errors As a fiduciary, Wealth Management LLC has the responsibility to effect orders correctly, promptly and in the best interests of our clients. In the event any error occurs in the handling of any client transactions, due to Wealth Management LLC 's actions, or inaction, or actions of others, Wealth Management LLC 's policy is to seek to identify and correct any errors as promptly as possible without disadvantaging the client or benefiting Wealth Management LLC in any way. If the error is the responsibility of Wealth Management LLC , any client transaction will be corrected and Wealth Management LLC will be responsible for any client loss resulting from an inaccurate or erroneous order. Any gains that result from trade errors are donated to a charitable organization. Wealth Management LLC 's policy and practice is to monitor and reconcile all trading activity, identify and resolve any trade errors promptly, document each trade error with appropriate supervisory approval and maintain a trade error file.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our trading policies and practices, disclosures and recordkeeping for the firm.

Procedure

Wealth Management LLC has adopted various procedures to implement the firm’s policy and reviews to monitor and insure the firm’s trading policies are observed, implemented properly and amended or updated, which include the following:

Trading reviews, reconciliations of any and all securities transactions for advisory clients.

Periodic supervisory reviews of the firm’s trading practices.

Periodic reviews of the firm’s Disclosure Document, advisory agreements, and other materials for appropriate disclosures of the firm’s trading practices and any conflicts of interests.

Designation of a Brokerage Committee, or other designated person, to review and monitor the firm’s trading practices.


1/1/2015 to Current

Valuations of Securities

Policy As a registered adviser and as a fiduciary to our advisory clients, Wealth Management LLC, has adopted this policy which requires that all client portfolios and investments reflect current, fair and accurate market valuations. Any pricing errors, adjustments or corrections are to be verified, preferably through independent sources or services, and reviewed and approved by the firm's designated person(s) or pricing committee.

Background As a fiduciary, our firm must always place our client's interests first and foremost and this includes pricing processes, which insure fair, accurate and current valuations of client securities of whatever nature. Proper valuations are necessary for accurate performance calculations and fee billing purposes, among others. Because of the many possible investments, various pricing services and sources and diverse characteristics of many investment vehicles, independent sources, periodic reviews and testing, exception reporting, and approvals and documentation or pricing changes are necessary with appropriate summary disclosures as to the firm's pricing policy and practices. Independent custodians of client accounts may serve as the primary pricing source.

Responsibility

Larry E. Hilkemann, or the firm's pricing committee, if any, has overall responsibility for the firm's pricing policy, determining pricing sources, pricing practices, including any reviews and re-pricing practices to help insure fair, accurate and current valuations.

Procedure


Wealth Management LLC utilizes, to the fullest extent possible, recognized and independent pricing services for timely valuation information for advisory client securities.

Whenever valuation information for specific, illiquid, foreign, private or other investments is not available through pricing services, Wealth Management LLC's designated officer, trader(s) or portfolio manager(s) will obtain and document price information from at least one independent source, whether it be a broker-dealer, bank, pricing service or other source.

Larry E. Hilkemann will arrange for periodic and frequent reviews of valuation information from whatever source to promptly identify any incorrect, stale or mispriced securities.

Any errors in pricing or valuations are to be resolved as promptly as possible, preferably upon a same day or next day basis, with repricing information obtained, reviewed and approved by the Larry E. Hilkemann or the firm's pricing committee.

A summary of the firm's pricing practices should be included in the firm's investment management agreement.

For securities where ready valuation information is not available e.g., hedge funds, private placements, illiquid securities, derivatives or other such situations are to be reviewed and priced by Larry E. Hilkemann or pricing committee in good faith to reflect the security's fair and current market value, and supporting documentation maintained.


1/1/2015 to Current

Whistleblower Complaints

Policy Wealth Management LLC has adopted procedures for receiving and reviewing employee whistleblower complaints pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act. Responsibility The Chief Compliance Officer has overall responsibility for the firm’s policy on employee whistleblower complaints. Procedures

All employee complaints concerning violations of the Advisers Act or any other provision of law, rule, order, standard, or prohibition prescribed by the SEC or any state securities authority should be reported to the Chief Compliance Officer. Wealth Management LLC encourages employees to submit complaints to the Firm before contacting the SEC or other regulatory agencies. This will give Wealth Management LLC the opportunity to begin investigating the problem as quickly as possible and may increase the amount of the award given to the whistleblower. Complaints may be reported anonymously, however, the Chief Compliance Officer will request that the employee put the complaint in writing, and include the exact nature, scope, and breadth of the accusation.

When such a complaint has been received by the Chief Compliance Officer, it will be brought before the Wealth Management Committee, and legal counsel may be contacted, if appropriate. The Committee will expeditiously investigate the complaint by obtaining all relevant documents and interviewing appropriate personnel. The whistleblower will be kept informed as to the progress of the investigation, but confidentiality will be maintained.

After the Committee has the reviewed the complaint, it will determine the appropriate action to take to remedy the situation. Wealth Management LLC will maintain records which contain all the information submitted with the complaint and a report detailing the investigation and the actions taken by the Committee as result of the complaint.

After the employee files a complaint, the Chief Compliance Officer will follow up with the employee to ensure that the employee has not been retaliated against. Any such retaliation will be documented and kept confidential. Wealth Management LLC will not tolerate any retaliation against employees for reporting complaints.


1/1/2015 to Current

Wrap Fee Adviser

Policy Wealth Management LLC does not act as an adviser or sub-adviser in any wrap fee program.

Background

A wrap fee program is defined as any program under which any client is charged a specified fee or fees not based directly upon transactions in a client’s account for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and execution of client transactions.

Wrap fee programs also typically include custody services as part of the all-inclusive services in the program.

Responsibility

Larry E. Hilkemann has the responsibility for insuring the firm's policy is followed and that Wealth Management LLC does not participate as an adviser/sub-adviser in any wrap fee programs unless appropriately approved and all regulatory requirements are met.

Procedure


Wealth Management LLC 's designated officer monitors the firm's businesses and advisory services, including periodic reviews of the firm's Form ADV and disclosures.

Wealth Management LLC 's designated officer also monitors the firm's advisory services to insure that participation in any wrap fee programs as an adviser/sub-adviser would only be allowed after appropriate management approvals, disclosures and meeting regulatory requirements.


1/1/2015 to Current

Wrap Fee Sponsor

Policy

Wealth Management LLC, as a matter of policy and practice, does not sponsor any wrap fee program, defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions.

Background

A wrap fee program is defined as any program under which any client is charged a specified fee or fees not based directly upon transactions in a client’s account for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and execution of client transactions. Wrap fee programs also typically include custody services as part of the all-inclusive services in the program.

Responsibility

Larry E. Hilkemann has the responsibility for the implementation and monitoring of our wrap fee policy that the firm prohibits sponsoring any wrap fee programs unless appropriately approved and all regulatory requirements are met.

Procedure


Wealth Management LLC 's designated officer monitors the firm's businesses and advisory services, including periodic reviews of the firm's Form ADV and disclosures to prohibit any arrangements from sponsoring any wrap fee program.

Wealth Management LLC 's designated officer also monitors the firm's advisory services to insure that any arrangements to sponsor any wrap fee program would only be allowed after appropriate management approvals, disclosures and meeting regulatory requirements.

S:\INTRANET\z-Wealth Management\Compliance\Manuals\Policy & Procedures\WM LLC\2015.01 WM Policies &Procedures - Current Version.doc