Waverly Advisors, LLC

• A percentage of assets under your management
• Hourly charges
• Fixed fees (other than subscription fees)
• Performance-based fees

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

See the firm's brochure (dated August 31, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$29,872,072,116 as of October 2026, filing dated August 31, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Financial planning services
• Portfolio management for individuals and/or small businesses
• Portfolio management for investment companies (and business development companies)
• Portfolio management for pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients
• Pension consulting services
• Selection of other advisers (including private fund managers)

Also doing business as

401K COMPLETE, PROMUS

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2001 (24 years)

Employees

Total: 414. Performing investment advisory functions: 197.

Wrap fee program participation

No.

Custodians (Schedule D, Section 5.K(3))

Charles Schwab & Co., Inc.Fidelity Brokerage Services LLC

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

Other offices (Schedule D, Section 1.F)

24 other offices, as of the September 2026 filing

Atlanta, GAAustin, TXBaltimore, MDBoston, MACharlotte, NCChicago, ILCincinnati, OHColorado Springs, COCouncil Bluffs, IADayton, OHHamilton, OHHuntsville, ALJacksonville, FLLake Oswego, ORLakeland, FLMerillville, INPaoli, PAPeachtree City, GAPensacola, FLRidgeland, MSSeattle, WAWest Barnstable, MAWesterville, OHZionsville, IN

States registered or notice-filed

51 states or jurisdictions

AKALARAZCACOCTDCDEFLGAHIIAIDILINKSKYLAMAMDMEMIMNMOMSMTNCNDNENHNJNMNVNYOHOKORPARISCTNTXUTVAVIVTWAWIWVWY

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

None Reports no disclosure items on Form ADV Item 11. View on IAPD.

Item 11 asks about criminal, regulatory, and civil events involving the firm and its advisory personnel. The detail of each yes answer is on the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $3,291,010,494 in the October 2021 data and $29,872,072,116 in the October 2026 data, up 808%.

Total employees: 49 in October 2021 and 414 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. September 2026
   • Updated its list of owners and control persons (Schedule A).
2. April 2026
   • Added an office in Boston, MA.
   • Added an office in Cincinnati, OH.
   • Added an office in Council Bluffs, IA.
   • Added an office in Hamilton, OH.
   • Added an office in Lake Oswego, OR.
   • Added an office in Seattle, WA.
   • No longer lists an office in Deerfield, IL.
   • No longer lists an office in Lafayette, IN.
   • No longer lists an office in Mobile, AL.
   • No longer lists an office in Montgomery, AL.
   • No longer lists an office in Oak Brook, IL.
   • No longer lists an office in Savannah, GA.
   • Updated its list of owners and control persons (Schedule A).
3. January 2026
   • Employees performing advisory functions went from 190 to 197.
   • Added the business name Promus.
   • Changed its office addresses in West Barnstable, MA.
   • Added an office in Austin, TX.
   • Added an office in Deerfield, IL.
   • Added an office in Lafayette, IN.
   • Added an office in Lakeland, FL.
   • Added an office in Montgomery, AL.
   • Added an office in Oak Brook, IL.
   • Added an office in Savannah, GA.
   • No longer lists an office in Boston, MA.
   • No longer lists an office in Canon City, CO.
   • No longer lists an office in Fairfield, OH.
   • No longer lists an office in Hamilton, OH.
   • No longer lists an office in Philadelphia, PA.
   • No longer lists an office in Sarasota, FL.
   • No longer lists an office in Seattle, WA.
4. December 2025
   • Regulatory assets under management went from $16,130,190,961 to $28,263,743,199 (+75%).
   • Employees performing advisory functions went from 152 to 190.
   • Added an office in Chicago, IL.
   • Added an office in West Barnstable, MA.
   • No longer lists an office in Lakeland, FL.
   • No longer lists an office in Savannah, GA.
   • Registered or notice-filed in VI.
   • Updated its list of owners and control persons (Schedule A).
5. November 2025
   • Added an office in Seattle, WA.
   • No longer lists an office in Doylestown, PA.

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.