ADDISON ADVISORS LLC

Item 1 – Cover Page Addison Advisors LLC doing business as (dba) Marble Trail Advisors 88 Main St P.O Box 30 Middlebury, VT 05753 (802) 388-6300 www.marbletrail.com July 2025 Form ADV Part 2 Brochure This Brochure provides information about the qualifications and business practices of Addison Advisors LLC dba Marble Trail Advisors. If you have any questions about the contents of this Brochure, please contact us at (802) 388-6300. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Marble Trail Advisors is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. 1 Additional information about Marble Trail Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes Since our last required annual amendment to this brochure filed in February 2025 the following material change has been made to this disclosure brochure: • In July 2025 the firm moved its office location to the addressed listed on the cover page of this brochure. • Item 15 – Custody for more specific In March 2024 the firm entered into a relationship with a client that established a “custody relationship” over the client assets. Please refer to information. Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Don Devost, Principal of Marble Trail Advisors at (802) 388-6300 or don@marbletrail.com. Our Brochure is also available on our website www.marbletrail.com, also free of charge. Additional information about Marble Trail Advisors is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Marble Trail Advisors who are registered, or are required to be registered, as investment adviser representatives of Marble Trail Advisors. 2  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................................................ 1 Item 2 – Material Changes ................................................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................................................... 3 Item 4 – Our Firm .................................................................................................................................................................................... 4 Item 5 – Fees and Compensation ...................................................................................................................................................... 5 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................................... 6 Item 7 – Types of Clients ...................................................................................................................................................................... 6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................ 7 Item 9 – Disciplinary Information .................................................................................................................................................... 7 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................................. 7 Item 11 – Code of Ethics ....................................................................................................................................................................... 8 Item 12 – Brokerage Practices ........................................................................................................................................................... 9 Item 13 – Review of Accounts .......................................................................................................................................................... 10 Item 14 – Client Referrals and Other Compensation .............................................................................................................. 10 Item 15 – Custody .................................................................................................................................................................................. 10 Item 16 – Investment Discretion..................................................................................................................................................... 11 Item 17 – Voting Client Securities .................................................................................................................................................. 11 Item 18 – Financial Information ...................................................................................................................................................... 12 3  Item 4 – Our Firm Marble Trail Advisors is a registered investment adviser based in Middlebury, VT. The firm was founded as Addison Advisors LLC in 2010 by Donald Devost. Matthew Wootten joined the firm in 2014. Donald and Matthew are the controlling owners and managers of the firm. INVESTMENT SERVICES Marble Trail Advisors is a fee-only investment advisory firm providing comprehensive wealth management services to individuals, families, and trusts who desire a deep long-term relationship with trusted financial professionals. Our holistic approach integrates financial planning and investment management. Financial Planning Our investment advisory services frequently begin with the preparation of a financial plan that identifies client goals and financial resources, analyzes the impact of client choices on the attainment of those goals, and identifies actions to achieve them. A typical financial plan will articulate savings, investment, and tax strategies to address retirement, education, and estate planning goals. When appropriate, Marble Trail will coordinate efforts with a client’s attorney, tax accountant, or insurance professional. Our services do not include legal counsel, asset custody, or the sale of any investment or insurance products. We view the financial plan as integral to the relationship and something we will update once a year, or whenever a client’s material financial circumstances or goals change. Investment Management Our investment advice is tailored to meet our clients’ needs and objectives. We document these in the Investment Policy Statement along with each client’s unique financial circumstances, risk tolerance and time horizon. Together these elements inform the investment approach that will maximize the client’s likelihood of attaining their goals. Our firm mainly uses equity securities, exchange traded funds, no-load mutual funds, corporate securities, municipal securities, and U.S. government securities in its portfolio management programs. We will monitor your portfolio’s performance on an ongoing basis and rebalance the portfolio whenever necessary, as changes occur in market conditions, your financial circumstances, or both. Our firm primarily offers discretionary portfolio management services, which means we make investment decisions and place buy or sell orders in client accounts without explicit prior approval. Any actions taken will be based upon stated investment objectives as documented in the investment policy statement. 4  Referral of Third-Party Money Managers For a portion of client accounts Marble Trail Advisors refers clients to a third-party money manager offering asset management and other investment advisory services. The third-party managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. Under this program, we assist you with identifying your risk tolerance and investment objectives. We recommend third-party money managers in relation to your stated investment objectives and risk tolerance, and you may select a recommended third-party money manager or model portfolio based upon your needs. You must approve in writing use of the third-party money manager who provides your designated account with asset management services. We are available to answer questions that you may have regarding your account and act as the communication conduit between you and the third-party money manager. The third-party money manager may take discretionary authority to determine the securities to be purchased and sold for your account. We do not have any trading authority with respect to your designated account managed by the third-party money manager. Clients are advised that there may be other third-party managed programs not recommended by our firm, that are suitable for the client and that may be more or less costly than arrangements recommended by our firm. No guarantees can be made that a client’s financial goals or objectives (Please refer to Item 8 – Methods of will be achieved by a third-party investment adviser recommended by our firm. Further, no Analysis, Investment Strategies and Risk of Loss for more details.) guarantees of performance can ever be offered by our firm Assets Under Management As of December 31. 2024, Marble Trail Advisors managed $490,221,306 of client assets, $486,840,223 are managed on a discretionary basis and $3,381,083 and managed on a non- discretionary basis. Item 5 – Fees and Compensation Marble Trail Advisors’ fee for comprehensive wealth management services includes a fixed fee for financial planning and an asset-based fee for investment management. The fee for financial planning depends on several factors including the scope, complexity and frequency of services provided. Marble Trail has established a minimum annual planning fee of $2,500 per household, but may negotiate a fee below the annual minimum where circumstances warrant. Our fees for investment management services range from an annualized rate of 0.30% to 1.00% based on total assets under Marble Trail management. The specific level of fees that will be paid is established in the investment advisory contract of each client. The fee schedule is subject to change upon prior written notice to the client. 5  Fees are paid quarterly in advance, and clients may terminate their contracts with written notice. At the point of termination, fees will be refunded on a prorated basis, based on the number of days remaining in a quarter. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Fees charged by Marble Trail may vary among its clients based upon the type of client, the services requested, the complexity of the client's situation, the composition of the client's account, other advisory services provided and the relationship of the client and the investment adviser representative. Marble Trail may waive or reduce a portion of the investment advisory fees. Any reduction will be at the discretion of Marble Trail and disclosed to client prior to contracting for investment advisory services. Marble Trail believes that its annual fee is reasonable in relation to services provided and the fees charged by other investment advisers offering similar services. Marble Trail’s annual wealth management fee may, however, be higher than that charged by other investment advisers offering similar services. Marble Trail’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Clients may also incur certain charges imposed by custodians, brokers, and third-party investment managers such as fees charged by managers, custodial fees, deferred sales charges, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Marble Trail Advisors' fee, and Marble Trail Advisors shall not receive any portion of these commissions, fees, or costs. Third-Party Money Managers A complete description of the third-party money manager’s services, fee schedules and account minimums will be disclosed in the third-party money manager’s disclosure brochure which will be provided to you prior to or at the time an agreement for services is executed and the account is established. The actual fee charged to you will vary depending on the third-party money manager. Marble Trail and the third-party managers are individually responsible for the calculation and collection of the investment management fees that they will charge. Marble Trails asset management fees will be based upon the fee schedule referenced above. Fees charged by Third Party Managers will be disclosed at the time the client signs an agreement with that firm. Item 6 – Performance-Based Fees and Side-By-Side Management Marble Trail Advisors does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of client assets). Item 7 – Types of Clients Marble Trail Advisors offers investment advisory services to individuals, high net worth individuals, corporate pension and profit-sharing plans, charitable institutions, foundations, 6  endowments, and trust programs. Some of our services may not be suitable to certain clients and clients will only be provided and billed for appropriate services. Third-party money managers may have minimum account and minimum fee requirements in order to participate in their programs. Each-third party money manager will disclose its minimum account size and fees in its Form ADV Part 2A Disclosure Brochure. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Marble Trail Advisors employs a fundamental, value-based approach that seeks to determine whether the potential returns of an investment are proportionate to its risks. In addition to assessing the merits of individual securities, the risk and return characteristics of the entire portfolio of a client’s investments are analyzed to ensure they are consistent with the client’s goals and risk tolerance, as described in the Investment Policy Statement. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Marble Trail Advisors or the integrity of Marble Trail Advisors’ management. Marble Trail Advisors has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Marble Trail Advisors is a fully owned subsidiary of Marble Trail Financial LLC. Marble Trail Financial is a tax, accounting, and business consulting firm. Donald Devost and Matthew Wootten are advisory representatives of Marble Trail Advisors as well as owners of Marble Trail Financial. Clients may be referred between these two firms; however, clients are under no obligation to use any services provided by the other firm. While employees of Marble Trail Financial are not paid a direct fee based on the actual referrals made to Marble Trail Advisors, Marble Trail Financial LLC benefits from the referral arrangement due to its direct ownership of Marble Trail Advisors. While employees of Marble Trail Advisors are not paid a direct fee based on the actual referrals made to Marble Trail Financial, Marble Trail Advisors benefits from the referral arrangement due to its managers’ direct ownership in Marble Trail Financial. The aforementioned relationship creates a conflict of interest that may affect the independent judgment of Marble Trail Advisors in its recommendation of accounting providers to clients. Material conflicts of interest will be disclosed to clients up front and all efforts will be made to put the interests of the client first. Third-Party Money Managers 7  Item 5 of this Items 4 and 5 for full details regarding the programs, fees, conflicts of Marble Trail Advisors has developed several programs, previously described in disclosure brochure, designed to allow us to recommend and select third-party money managers for you. Please refer to interest and materials arrangements when Marble Trail Advisors selects other investment advisers. Item 11 – Code of Ethics Marble Trail Advisors has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. YOU HAVE A RIGHT TO SEE OUR CODE OF ETHICS. FOR A COPY OF THE CODE OF ETHICS, PLEASE ASK YOUR ADVISER AT MARBLE TRAIL ADVISORS AT ANY TIME. From time to time, representatives of Marble Trail Advisors may buy or sell securities for themselves that they also recommend to clients. (See Employee Trading) Marble Trail Advisors always documents any transactions that could be construed as a conflict of interest and transacts client business before their own when similar securities are being bought or sold. Marble Trail Advisors does everything possible to mitigate these conflicts by disclosing to the client any possible conflict of interest. Marble Trail Advisors acts in a fiduciary manner, and always acts in the client’s best interest. Employee Trading Marble Trail Advisors’ employee trading policy stipulates that client trades take priority over employee trades. The following procedures have been put into place: • • If Marble Trail Advisors is purchasing or considering for purchase any security on behalf of Marble Trail Advisors’ clients, none of Marble Trail Advisors’ employees or officers may effect for himself or herself or for his or her immediate family transactions in that security prior to the completion of client purchases, or until a decision has been made not to purchase the security on behalf of clients; and If Marble Trail Advisors is selling or considering the sale of any security on behalf of Marble Trail Advisors’ clients, no employees may trade in that security prior to the completion of the sales on behalf of the clients. The following exceptions have been identified: • Some securities purchased or sold on behalf of Marble Trail Advisors’ clients trade in sufficiently broad markets to permit transactions to be completed without any appreciable impact on the markets of the securities. 8  • Open-end mutual funds are purchased or redeemed at a fixed net asset value price per share specific to the date of purchase or redemption. Transactions in mutual funds by employees are not likely to have an impact on share prices of the funds and are not restricted by Marble Trail Advisors’ Compliance Policies and Procedures. Item 12 – Brokerage Practices Marble Trail Advisors does not maintain custody of the assets that we manage on our clients’ behalf, though we may be deemed to have custody of those assets when clients grant us authority to withdraw our management fee from their accounts. Client assets must be maintained in an account at a “qualified custodian,” generally a broker or bank. We request that our clients use as the qualified custodian either Pershing Advisor Solutions, LLC (Pershing) or Charles Schwab & Co., Inc. (Schwab). Both are FINRA-registered broker-dealers, members SIPC. We are independently owned and operated and not affiliated with either Pershing or Schwab. Either will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we request that you use either Pershing or Schwab as custodian/broker, you will decide whether to do so by entering into an account agreement directly with them. When recommending a custodian who will hold your assets, Marble Trail Advisors considers a range of factors including breadth of investment products, transaction fees, trade execution, reputation and financial strength, and quality of service to our clients. For our clients’ accounts they maintain, neither Pershing nor Schwab charge you separately for custody services but may be compensated by charging you commissions or other fees on trades that it executes or that settle into your brokerage account. Marble Trail Advisors never charges a premium or commission on transactions beyond the actual cost imposed by the Custodian. In addition to commissions, Pershing and Schwab charge you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your brokerage account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have your chosen Custodian execute most trades for your account. Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. 9 Pershing Advisor Solutions is a wholly owned subsidiary of Bank of New York Mellon. Pershing serves independent investment advisory firms like us, providing us and our clients with access to its institutional brokerage – trading, custody, reporting and related services. These services are not available directly to retail customers. We have entered into a Support Services Agreement with Pershing. Under the terms of the agreement, Pershing will provide certain support services as well as monetary payments that are intended to support us in managing and servicing client  accounts on the Pershing platform. To be eligible for this support, assets on the platform must reach certain levels. While we endeavor at all times to put client interests first, the receipt of economic benefits by Marble Trail Advisors creates a potential conflict of interest and may indirectly influence our recommendation of Pershing for custody and brokerage services. Item 13 – Review of Accounts Client accounts are reviewed at least quarterly by the firm’s principals and/or representatives. All accounts at Marble Trail Advisors are assigned to one of the principals or representatives as the primary reviewer of the account, although in practice both principals and representatives will occasionally review each other’s accounts. Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Each client receives a quarterly report from Marble Trail Advisors detailing that client’s account performance. Accounts established and maintained with other third-party money managers are reviewed at least quarterly, usually when statements and/or reports are received from the money manager. Item 14 – Client Referrals and Other Compensation As referenced in Item 10 above, advisory representatives of Marble Trail Advisors may receive an economic benefit from referring clients to Marble Trail Financial for accounting and tax preparation services. Furthermore, owners of Marble Trail Financial may receive an economic benefit from referring clients to Marble Trail Advisors for investment advisory services. Clients, however, are under no obligation to use any services provided by either firm. Marble Trail Advisors does not directly or indirectly compensate any person for client referrals other than the owners of Marble Trail Financial. Marble Trail Advisors has no arrangements, either oral or in writing, where it is paid cash by or receives some economic benefit (including commissions, equipment, or non-research services) from a non-client in connection with giving investment advice to clients. Marble Trail Advisors’ Chief Compliance Officer, Donald H. Devost, is available to address any questions that a client or prospective client may have regarding the above arrangements and any perceived conflict of interest any such arrangements may create. Item 15 – Custody 10 Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment adviser has the ability to access or control client funds or securities, the investment adviser is deemed to have custody and must ensure proper procedures are implemented.  When fees are deducted from an account, Marble Trail Advisors is responsible for calculating the fee and delivering instructions to the custodian. At the same time Marble Trail Advisors instructs the custodian to deduct fees from your account; Marble Trail Advisors will send you an invoice itemizing the fee. Itemization will include the formula used to calculate the fee, the amount of assets under management the fee is based on, and the time period covered by the fee. Marble Trail Advisors is deemed to have custody of client funds and securities whenever it is given the authority to have fees deducted directly from client accounts. In addition, there are a small number of Marble Trail Advisors client arrangements where representatives of Marble Trail Advisors serve as trustee for the client. The role of trustee is imputed (or “assigned”) to Marble Trail Advisors and therefore we are deemed to have custody of those client funds and securities. The firm has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client (other than the Marble Trail Advisors affiliated trustee) are also notified, in writing of the qualified custodian’s name, address and the manner in which the funds or securities are maintained, promptly when the account is opened and following any changes. Account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative (other than the Adviser affiliated trustee), at least quarterly. Finally, affiliated trustee accounts managed by us are subject to an annual surprise verification examination conducted by a third-party, independent accounting firm. Marble Trail Advisors is deemed to have custody of client funds and securities when Marble Trail Advisors has standing authority (also known as a standing letter of authorization or “SLOA”) to move money from a client’s account to a third-party account. Item 16 – Investment Discretion It is Marble Trail Advisors’ belief that clients should be informed and understand each of the investments made on their behalf. For the sake of convenience, however, certain clients grant Marble Trail Advisors discretionary trading authority. When granted, this is established in the client’s Investment Advisory Contract with Marble Trail Advisors. Under this arrangement, Marble Trail Advisors has the authority to determine which securities are bought or sold and the quantity of securities bought and sold. For clients with non-discretionary accounts, Marble Trail Advisors proposes trades to the client. These are reviewed with the client and the client’s approval of the trade is given before being executed by Marble Trail Advisors. Item 17 – Voting Client Securities As a matter of firm policy and practice, Marble Trail Advisors does not vote proxies on behalf of advisory clients unless explicitly authorized by clients to do so. All other clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Marble Trail Advisors may provide advice to clients regarding the clients’ voting of proxies. 11  With respect to assets managed by a third-party money manager, we will not vote the proxies associated with these assets. You will need to refer to each third-party money manager’s disclosure brochure to determine whether the third-party money manager will vote proxies on your behalf. You may request a complete copy of third-party money manager’s proxy voting policies and procedures as well as information on how your proxies were voted by contacting the third-party money manager or by contacting Marble Trail Advisors at the address or phone number indicated on Page 1 of this disclosure document. Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about Marble Trail Advisors’ financial condition. Marble Trail Advisors has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 12