Overview

Assets Under Management: $158 million
Headquarters: WESTPORT, CT
High-Net-Worth Clients: 21
Average Client Assets: $5 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ALPINE HILL DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENTS)

MinMaxMarginal Fee Rate
$0 and above 1.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $15,000 1.50%
$5 million $75,000 1.50%
$10 million $150,000 1.50%
$50 million $750,000 1.50%
$100 million $1,500,000 1.50%

Clients

Number of High-Net-Worth Clients: 21
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 94.57
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 106
Discretionary Accounts: 106

Regulatory Filings

CRD Number: 325412
Last Filing Date: 2024-08-15 00:00:00
Website: https://alpinehilladvisors.com

Form ADV Documents

Primary Brochure: ALPINE HILL DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENTS (2025-03-21)

View Document Text
Alpine Hill Advisors LLC Form ADV Part 2A – Disclosure Brochure Effective: March 21, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Alpine Hill Advisors LLC (“Alpine Hill” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (203) 429-0406. Alpine Hill is a registered investment advisor with the U.S. Securities and Exchange Commission. The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Alpine Hill to assist you in determining whether to retain the Advisor. Additional information about Alpine Hill and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 325412. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Alpine Hill. For convenience, the Advisor has combined these documents into a single disclosure document. Alpine Hill believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Alpine Hill encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on March 8th, 2024: • Item 7: The advisor has updated its general minimum relationship size to $1,000,000. This can be reduced at the sole discretion of the advisor. • Effective April 30, 2024, the Advisor has appointed Brandon Pacilio as Chief Compliance Officer and sole owner of Alpine Hill Advisors LLC. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 325412. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (203) 429-0406. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 2 Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................. 1 Item 2 – Material Changes....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 3 Item 4 – Advisory Services ..................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 6 D. Wrap Fee Programs ........................................................................................................................................................ 6 E. Assets Under Management ............................................................................................................................................. 6 Item 5 – Fees and Compensation ........................................................................................................................... 6 A. Fees for Advisory Services.............................................................................................................................................. 6 B. Fee Billing........................................................................................................................................................................ 7 C. Other Fees and Expenses .............................................................................................................................................. 7 D. Advance Payment of Fees and Termination ................................................................................................................... 7 E. Compensation for Sales of Securities ............................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................... 8 Item 7 – Types of Clients......................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8 A. Methods of Analysis ........................................................................................................................................................ 8 B. Risk of Loss ..................................................................................................................................................................... 8 Item 9 – Disciplinary Information ......................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 10 A. Code of Ethics ............................................................................................................................................................... 10 B. Personal Trading with Material Interest ......................................................................................................................... 10 C. Personal Trading in Same Securities as Clients ........................................................................................................... 10 D. Personal Trading at Same Time as Client .................................................................................................................... 11 Item 12 – Brokerage Practices ............................................................................................................................. 11 A. Recommendation of Custodian[s] ................................................................................................................................. 11 B. Aggregating and Allocating Trades ............................................................................................................................... 12 Item 13 – Review of Accounts .............................................................................................................................. 12 A. Frequency of Reviews ................................................................................................................................................... 12 B. Causes for Reviews ...................................................................................................................................................... 12 C. Review Reports ............................................................................................................................................................. 12 Item 14 – Client Referrals and Other Compensation ......................................................................................... 12 A. Compensation Received by Alpine Hill ......................................................................................................................... 12 B. Client Referrals from Solicitors ...................................................................................................................................... 14 Item 15 – Custody .................................................................................................................................................. 14 Item 16 – Investment Discretion ........................................................................................................................... 14 Item 17 – Voting Client Securities ........................................................................................................................ 15 Item 18 – Financial Information ............................................................................................................................ 15 Form ADV 2B – Brochure Supplements .............................................................................................................. 16 Privacy Policy......................................................................................................................................................... 20 Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 3 Item 4 – Advisory Services A. Firm Information Alpine Hill Advisors LLC (“Alpine Hill” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Connecticut in February 2023. Alpine Hill is owned and operated by Brandon T. Pacilio (Managing Partner and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Alpine Hill. B. Advisory Services Offered Alpine Hill offers wealth management and family office services to individuals, high net worth individuals, trusts, estates, and businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Alpine Hill's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Alpine Hill provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management, financial planning, and related advisory services. Alpine Hill’s investment philosophy and approach are based on a fundamental belief in transparency and cost efficiency. The focus of the investment approach is predicated on determining the appropriate asset allocation of the Client based on numerous factors. The first step in the investment process is a discovery meeting with the Client to determine their financial needs, objectives, investment horizon, and risk tolerance. An investment plan is then implemented and includes monitoring, rebalancing, and making changes as the Client’s goals and objectives change. Underlying investments in Client portfolios may include, but are not limited to, individual fixed-income securities, individual stocks, exchange-traded funds (“ETFs”), mutual funds, private equity funds/alternative investments. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Alpine Hill’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Alpine Hill will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Alpine Hill evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Alpine Hill may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Alpine Hill may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Alpine Hill may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 4 Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services Alpine Hill will typically provide a variety of financial planning and consulting services to Clients as part of its wealth management services. Certain complex engagements may be offered under a separate agreement and fee. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Alpine Hill may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Family Office – Lifestyle Management Services For certain Clients, the Advisor offers additional services to assist the Client with management of various personal and family needs (herein collectively “Lifestyle Management Services”). These services shall include, but are not limited to: • Bill Payment • Calendar Management • Philanthropic Management • Travel Management • Concierge Services To provide these services, the Advisor will require additional access to the Client’s accounts and the authority to make payments from these accounts. This level of access is considered custody under the securities laws. Please see Item 15 – Custody. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 5 C. Client Account Management Prior to engaging Alpine Hill to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Alpine Hill, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Alpine Hill will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Alpine Hill will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Alpine Hill will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Alpine Hill does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Alpine Hill. E. Assets Under Management As of December 31, 2024, the Advisor manages $115,275,174 in assets under management, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid monthly in advance of each month, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior month. Wealth management fees range up to 1.50% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Alpine Hill will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Lifestyle Management Services Lifestyle management fees are paid monthly in advance of each month, pursuant to the terms of agreement. Fees range from $50,000 to $500,000 annually based on the scope of services and the level of activity and staffing required. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 6 B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the start of the monthly period. The amount due is calculated by applying the monthly rate (annual rate divided by 12) to the total assets under management with Alpine Hill at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to also review the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Alpine Hill to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Lifestyle Management Services Lifestyle management fees are paid monthly in advance of each month and are either deducted from a designated account at the Custodian or invoiced to the Client. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Alpine Hill, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. Fidelity, does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, Fidelity typically charges for mutual funds and other types of investments. LPL, charges securities transaction fees for ETFs and equity trades in a Client’s account. LPL also typically charges on mutual funds and other types of investments. The fees charged by Alpine Hill are separate and distinct from these custody and execution fees. In addition, all fees paid to Alpine Hill for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Alpine Hill, but would not receive the services provided by Alpine Hill which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Alpine Hill to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Alpine Hill may be compensated for its investment management services in advance of the month in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the month. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Lifestyle Management Services Lifestyle management fees are paid advance of each month, pursuant to the terms of agreement. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the month. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 7 E. Compensation for Sales of Securities Alpine Hill does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the wealth management fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Alpine Hill does not charge performance-based fees for its investment advisory services. The fees charged by Alpine Hill are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Alpine Hill does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Alpine Hill offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses. Alpine Hill generally requires a minimum relationship size of $1,000,000, which may be reduced at the sole discretion of the Advisor. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Alpine Hill primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Alpine Hill are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Alpine Hill will be able to accurately predict such a reoccurrence. As noted above, Alpine Hill generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Alpine Hill will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Alpine Hill may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Alpine Hill will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 8 While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 9 Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Alpine Hill or its management persons. Alpine Hill values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 325412. Item 10 – Other Financial Industry Activities and Affiliations The sole business of Alpine Hill is to provide investment advisory services to its Clients. Neither Alpine Hill nor its Advisory Persons are involved in other business endeavors. Alpine Hill does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Alpine Hill has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Alpine Hill (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Alpine Hill and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Alpine Hill’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (203) 429-0406. B. Personal Trading with Material Interest Alpine Hill allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Alpine Hill does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Alpine Hill does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Alpine Hill allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Alpine Hill requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 10 D. Personal Trading at Same Time as Client While Alpine Hill allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Alpine Hill, or any Supervised Person of Alpine Hill, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Alpine Hill does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Alpine Hill to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, Alpine Hill does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Alpine Hill does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Alpine Hill. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Alpine Hill may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Alpine Hill will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”). Fidelity is a FINRA-registered broker-dealer and member of SIPC. Fidelity will serve as the Client’s “qualified custodian”. Alpine Hill maintains institutional relationships with Fidelity, whereby the Advisor receives certain economic benefits. Alpine Hill has established the institutional relationships with Fidelity to assist the Advisor in managing Client accounts. Access to the respective Fidelity platform is provided at no charge to the Advisor. The platform includes brokerage, custody, administrative support, recordkeeping, technology, and related services designed to support registered investment advisors like Alpine Hill. These services are intended to serve the best interests of the Advisor’s Clients. Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no-load funds at nominal transaction charges. The commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. Alpine Hill may also recommend that Clients establish their accounts at LPL Financial. LPL Financial is a FINRA- registered broker-dealer and member of SIPC. LPL Financial will serve as the Client’s “qualified custodian.” Alpine Hill maintains an institutional relationship with LPL Financial, whereby the Advisor receives certain benefits. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Alpine Hill does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from Fidelity and LPL Financial. Please see Item 14 below. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 11 2. Brokerage Referrals - Alpine Hill does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Alpine Hill will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Alpine Hill will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Alpine Hill will execute its transactions through the Custodian as authorized by the Client. Alpine Hill may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons and periodically by the CCO of Alpine Hill. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Alpine Hill if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Alpine Hill Alpine Hill is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Alpine Hill does not receive commissions or other compensation from product sponsors, broker-dealers or any un- related third party. Alpine Hill may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Alpine Hill may receive non-compensated referrals of new Clients from various third-parties. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 12 Participation in Institutional Advisor Platform (Fidelity) Alpine Hill has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. Participation in the Institutional Advisor Platform Alpine Hill has established an institutional relationship with LPL Financial to assist the Advisor in managing Client account[s]. Access to the LPL Financial platform is provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at LPL Financial. The software and related systems support may benefit the Advisor but not its Clients directly. Further, LPL Financial has provided the Advisor with financial support in the start-up of this registered investment advisor. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Alpine Hill receives support services and/or products from LPL Financial, many of which assist the Advisor to better monitor and service program accounts maintained at LPL Financial; however, some of the services and products benefit the Advisor and not the Clients’ accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate and may include the following: investment-related research software and other technology that provides access to client account data compliance and/or practice management-related publications consulting services computer hardware and/or software • • pricing information and market data • • • • attendance at conferences, meetings, and other educational and/or social events • marketing support • • other products and services used by Alpine Hill in furtherance of its investment advisory business operations LPL Financial may provide these services and products directly or may arrange for third-party vendors to provide the services or products to Advisor. In the case of third-party vendors, LPL Financial may pay for some or all of the third party’s fees. These support services are provided to Alpine Hill based on the overall relationship between the Advisor and LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements with LPL Financial that Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 13 involve the execution of Client transactions as a condition to the receipt of services. Alpine Hill will continue to receive the services regardless of the volume of Client transactions executed with LPL Financial. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by the Advisor to LPL or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. However, because Advisor receives these benefits from LPL Financial, there is a potential conflict of interest. The receipt of these products and services presents a financial incentive for Advisor to recommend that its Clients use LPL Financials’ custodial platform rather than another custodian’s platform. B. Client Referrals from Solicitors Alpine Hill may compensate unaffiliated third parties for Client referrals. If a Client is introduced to the Advisor by either an unaffiliated or affiliated party (herein a “Promoter”), the Advisor compensates that Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client." Item 15 – Custody The Advisor is considered to have custody under the following circumstances and is consequently required to undergo an annual surprise examination. Lifestyle Management Services - Certain Clients may also engage the Advisor for Lifestyle Management Services (Please see Item 4). In connection with these services, the Advisor will have access to the Client’s bank and/or brokerage accounts and the authority to make payments from those accounts on a Client’s behalf. This level is access is deemed custody under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The mitigate the conflicts and risks associated with custody, the Advisor has engaged an independent auditing firm that will perform an annual, unannounced audit to review these associated accounts and transactions. Additionally, the Advisor is considered to have custody under the following limited circumstances. However, specific safeguards have been implemented to ensure that the associated Clients and accounts are exempt from an annual surprise examination. Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Alpine Hill exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Alpine Hill to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Alpine Hill to ensure accuracy, as the Custodian does not perform this review. Money Movement Authorization - For instances where Clients authorize Alpine Hill to move funds between their accounts, Alpine Hill and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion Alpine Hill generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Alpine Hill. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by Alpine Hill will be in accordance with each Client's investment objectives and goals. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 14 Item 17 – Voting Client Securities Alpine Hill does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Alpine Hill, nor its management, have any adverse financial situations that would reasonably impair the ability of Alpine Hill to meet all obligations to its Clients. Neither Alpine Hill, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Alpine Hill is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 15 Form ADV Part 2B – Brochure Supplement for Brandon T. Pacilio Managing Partner and Chief Compliance Officer Effective: March 21, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Brandon T. Pacilio (CRD# 5836773) in addition to the information contained in the Alpine Hill Advisors LLC (“Alpine Hill” or the “Advisor”, CRD# 325412) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Alpine Hill Disclosure Brochure or this Brochure Supplement, please contact us at (203) 429-0406 or by email at contact@clapboardhill.com. Additional information about Mr. Pacilio is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5836773. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 16 Item 2 – Educational Background and Business Experience Brandon T. Pacilio, born in 1992, is dedicated to advising Clients of Alpine Hill as a Managing Partner and Chief Compliance Officer. Mr. Pacilio earned a Bachelor of Arts from Middlebury College in 2014. Additional information regarding Mr. Pacilio’s employment history is included below. Employment History: Managing Partner and Chief Compliance Officer, Alpine Hill Advisors LLC Business Strategist, B. Riley Wealth Advisors, Inc. Client Services, National Securities Corp Client Services, National Asset Management Client Services, Bridgewater Associates, LP Associate, SumRidge Partners, LLC 03/2023 to Present 07/2022 to 03/2023 01/2020 to 07/2022 05/2020 to 07/2022 11/2018 to 08/2019 07/2014 to 10/2018 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Pacilio. Mr. Pacilio has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Pacilio. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Pacilio. However, we do encourage you to independently view the background of Mr. Pacilio on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5836773. Item 4 – Other Business Activities Mr. Pacilio is dedicated to the investment advisory activities of Alpine Hill’s Clients. Mr. Pacilio does not have any other business activities. Item 5 – Additional Compensation Mr. Pacilio is dedicated to the investment advisory activities of Alpine Hill’s Clients. Mr. Pacilio does not receive any additional forms of compensation. Item 6 – Supervision Mr. Pacilio serves as a Managing Partner and Chief Compliance Officer of Alpine Hill. Mr. Pacilio can be reached at (203) 429-0406. Alpine Hill has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Alpine Hill. Further, Alpine Hill is subject to regulatory oversight by various agencies. These agencies require registration by Alpine Hill and its Supervised Persons. As a registered entity, Alpine Hill is subject to examinations by regulators, which may be announced or unannounced. Alpine Hill is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 17 Form ADV Part 2B – Brochure Supplement for David S. Heiss Senior Client Relationship Manager Effective: March 21, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of David S. Heiss (CRD# 1429489) in addition to the information contained in the Alpine Hill Advisors LLC (“Alpine Hill” or the “Advisor”, CRD# 325412) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Alpine Hill Disclosure Brochure or this Brochure Supplement, please contact us at (203) 429-0406. Additional information about Mr. Heiss is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1429489. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 18 Item 2 – Educational Background and Business Experience David S. Heiss, born in 1963, is dedicated to advising Clients of Alpine Hill as a Senior Client Relationship Manager. Mr. Heiss earned a Bachelor’s Degree from Baruch in 1985. Additional information regarding Mr. Heiss’s employment history is included below. Employment History: Senior Client Relationship Manager, Alpine Hill Advisors LLC Financial Advisor, Morgan Stanley & Co. LLC Unemployed 05/2024 to Present 07/2020 to 05/2024 05/2019 to 07/2020 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Heiss. Mr. Heiss has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Heiss. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Heiss. However, we do encourage you to independently view the background of Mr. Heiss on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1429489. Item 4 – Other Business Activities Mr. Heiss is dedicated to the investment advisory activities of Alpine Hill’s Clients. Mr. Heiss does not have any other business activities. Item 5 – Additional Compensation Mr. Heiss is dedicated to the investment advisory activities of Alpine Hill’s Clients. Mr. Heiss does not receive any additional forms of compensation. Item 6 – Supervision Mr. Heiss serves as a Senior Client Relationship Manager of Alpine Hill and is supervised by Brandon Pacilio, the Chief Compliance Officer. Mr. Pacilio can be reached at (203) 429-0406. Alpine Hill has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Alpine Hill. Further, Alpine Hill is subject to regulatory oversight by various agencies. These agencies require registration by Alpine Hill and its Supervised Persons. As a registered entity, Alpine Hill is subject to examinations by regulators, which may be announced or unannounced. Alpine Hill is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 19 Privacy Policy Effective: March 21, 2025 Our Commitment to You Alpine Hill Advisors LLC (“Alpine Hill” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Alpine Hill (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Alpine Hill does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 20 How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Yes Yes No Not Shared Marketing Purposes Alpine Hill does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Alpine Hill or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Alpine Hill does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (203) 429-0406. Alpine Hill Advisors LLC 1 Turkey Hill Road South, Suite 204, Westport, CT 06880 Phone: (203) 429-0406 | Website: https://alpinehilladvisors.com Page 21