FIRM BROCHURE - ADV PART 2A

5899 PRESTON RD, STE. 1103 FRISCO, TX 75034 (214) 988-9178 WWW.BRINDLEANDBAY.COM FORM ADV PART 2A FIRM BROCHURE OCTOBER 5, 2026 Item 1 – Cover Page This brochure provides information about the qualifications and business practices of Brindle & Bay Financial Advisors. If you have any question about the contents of this brochure, please contact us at (214) 988-9178. 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. Brindle & Bay Financial Advisors is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Brindle & Bay Financial Advisors is available on the SEC’s website www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Brindle & Bay Financial Advisors, LLC. CRD number is 291747. Brindle & Bay Financial Advisors Page 1 ADV Part 2A – 10/5/2026  Item 2 - Material Changes Since our last annual update dated, March 23, 2026, we have made the following changes: • Advisory Services and Investment Process. We revised Items 4 and 8 to more accurately describe our ongoing financial planning and discretionary investment management services, including our use of model portfolios. We also added disclosure regarding our use of Advisor 123, a third-party service provider that assists with the design and testing of our investment models and provides advice regarding model rebalancing. We retain responsibility for determining whether models and recommended changes are appropriate for our clients and for implementing investment decisions in client accounts. We also removed prior disclosure regarding participation in the Altruist Model Marketplace because we do not use that service. • Fees and Account Minimums. We revised Items 5 and 7 to clarify our fee and account- minimum practices, including our $10,000 minimum annual advisory fee, our general $1,000,000 minimum asset requirement, and our practices regarding the aggregation or “householding” of related accounts for purposes of applying our tiered fee schedule. We also clarified that we pay Advisor 123 directly and that clients do not incur additional fees as a result of our use of Advisor 123. • Altruist Conflict of Interest. We revised Item 10 to provide additional information regarding the conflict of interest arising from our owner's personal investment in Altruist Corporation, the parent company of Altruist Financial LLC, which serves as our recommended custodian and broker-dealer, and the measures we use to address that conflict. • Brokerage Practices and Best Execution. We substantially revised Item 12 to more fully describe our brokerage practices and our process for periodically evaluating the quality of execution received through Altruist. The revised disclosure also addresses our consideration of alternative brokerage arrangements, conflicts associated with our relationship with Altruist, directed brokerage, and our procedures for aggregating and allocating client trades. As of October 5, 2026, our firm managed approximately $302,781,000 in client assets on a discretionary basis. Brindle & Bay Financial Advisors Page 2 ADV Part 2A – 10/5/2026  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 - Material Changes ............................................................................................................................. 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 4 Item 5 – Fees and Compensation ................................................................................................................. 5 Item 6 – Performance-Based Fees and Side by Side Management .............................................................. 7 Item 7 – Types of Clients ............................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 7 Item 9 – Disciplinary Information ................................................................................................................. 9 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 9 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 10 Item 12 – Brokerage Practices .................................................................................................................... 11 Item 13 – Review of Accounts ..................................................................................................................... 12 Item 14 – Client Referrals and Other Compensation .................................................................................. 13 Item 15 – Custody ....................................................................................................................................... 13 Item 16 – Investment Discretion ................................................................................................................ 13 Item 17 – Voting Client Securities ............................................................................................................... 14 Item 18 – Financial Information .................................................................................................................. 14 Brindle & Bay Financial Advisors Page 3 ADV Part 2A – 10/5/2026  Item 4 – Advisory Business OWNERSHIP/ADVISORY HISTORY Brindle & Bay Financial Advisors is a limited liability company formed under the laws of the State of Texas in January 2018. Nicolas D. Davis is our principal owner. ADVISORY SERVICES OFFERED We provide ongoing financial planning and discretionary investment management services designed to help clients achieve their long-term financial goals. Our services are tailored to each client's unique financial circumstances, objectives, risk tolerance, time horizon, and other relevant factors. Financial Planning As part of our ongoing financial planning services, we work closely with clients to evaluate their overall financial situation, establish goals and priorities, and develop strategies designed to help them achieve those objectives. Financial planning may address a variety of topics depending on the client's needs, including retirement planning, cash flow, tax planning, investment allocation, insurance, estate planning considerations, charitable giving, education funding, employer- sponsored retirement plans, Social Security, and other financial matters. Financial planning is an ongoing process. We periodically review and update each client's financial plan, generally at least annually or more frequently as appropriate based on changes in the client's financial circumstances or objectives. for determining whether and how to As part of the financial planning process, we may provide investment recommendations regarding employer-sponsored retirement plans, qualified retirement accounts, or other assets that are not managed by us ("held-away assets"). Clients retain full authority over these accounts and are solely responsible implement our recommendations. Investment Management We provide continuous discretionary investment management services for client accounts over which we have been granted discretionary authority. Based upon each client's investment objectives, financial circumstances, risk tolerance, time horizon, liquidity needs, tax considerations, and any reasonable investment restrictions established by the client, we construct and manage individualized investment portfolios. We use a third-party money manager, Advisor 123 LLC (“Advisor 123”) as a third-party model provider to assist with the design and testing of investment models and to provide advice regarding model rebalancing. We retain responsibility for determining whether each model and any recommended changes are appropriate for our clients and for implementing investment decisions in client accounts. Brindle & Bay Financial Advisors Page 4 ADV Part 2A – 10/5/2026  Portfolios may consist of exchange-traded funds, mutual funds, individual equity securities, fixed income securities, money market funds, and other investments we believe are appropriate for the client's objectives. We monitor client portfolios on an ongoing basis and make investment decisions, including purchases, sales, rebalancing, and other portfolio adjustments, without obtaining prior client approval for each transaction, consistent with the authority granted under the client's advisory agreement. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industries, provided such restrictions are communicated to us in writing and accepted by the firm. We will make a reasonable attempt to honor any restrictions you request, but in the case of pooled investment vehicles, such as mutual funds or exchange-traded funds where underlying holdings change frequently, we cannot guarantee restrictions will always be enforced. In addition, such restrictions could cause us to deviate from the investment decisions we would otherwise make in managing your account. In some cases, we could be unable to accommodate restrictions if they do not allow us to manage your portfolio in a prudent manner. TAILORED SERVICES The goals and objectives for each client are documented before any investing takes place. Clients may impose restrictions on investing in certain securities or types of securities. WRAP PROGRAM We do not sponsor a wrap program. CLIENT ASSETS MANAGED As of October 5, 2026, our firm managed approximately $302,781,000 in client assets on a discretionary basis. Item 5 – Fees and Compensation We charge an annual investment management fee based upon a percentage of assets under management in your account. Our standard annual management fee schedule is: Custodian Reported Account Value Annual Management Fee First $1,000,000 Next $2,000,000 Next $2,000,000 Over $5,000,000 1.25% 0.80% 0.50% 0.30% Our management fee schedule is tiered. Tiered fee schedule means the applicable rate will be applied to the applicable range of account value. For example, an account value of $2,000,000 at the end of the billing period will be charged at a rate of 1.25% on the first $1,000,000 and 0.80% on the remaining $1,000,000. Brindle & Bay Financial Advisors Page 5 ADV Part 2A – 10/5/2026  For purposes of determining the applicable advisory fee rate and asset-based fee breakpoints, Adviser may aggregate accounts maintained by the same client and accounts of related family or household members, as applicable. Accounts that are aggregated for this purpose are treated as a single household when applying the tiered fee schedule. Our fee is subject to an annual minimum of $10,000, generally payable in monthly installments. If the asset-based fee calculated for a billing period is less than the applicable portion of the minimum fee, we may charge the difference. We may waive or reduce the minimum fee at our discretion. Any waiver or reduction does not obligate us to provide a similar waiver or reduction to another client or during a future billing period. Our management fee is calculated and collected monthly in arrears. The fee is based on the value of the assets in your account as of the last trading day of each month, as reported by the qualified custodian. Balances held in cash, money market funds, and other cash equivalents are included in the fee calculation. Assets held in Altruist High Yield Savings Accounts are excluded from the fee calculation. Clients authorize us to instruct the qualified custodian to deduct our advisory fee directly from their account. Our management fee is negotiable based on account size, the scope of services provided, and other individual client circumstances. We reserve the right to offer fee waivers or discounts, including flat monthly fee rates, at our discretion. Our annual management fee is negotiable, depending on circumstances. We pay Advisor 123 directly for its services. Clients do not pay any additional advisory fees or other charges as a result of our use of Advisor 123. The management fee does not include transaction charges, and other related costs and expenses that are incurred by the client. Clients may incur custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, 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 our management fee and we do not receive any portion of these commissions, fees, and costs. For more information about our recommended brokerage practice please see Item 12.A. Either party may terminate the Investment Management Agreement by giving ten (10) days written notice. Upon termination, fees will be prorated for the number of days in which services were rendered on the Account’s valuation as of the termination date. The written notice of termination must be sent to Brindle & Bay Financial Advisors, 5899 Preston Rd, Ste. 1103 Frisco, TX 75034 or by email to memberservice@brindleandbay.com. Upon our receipt of written notice of termination, the client will be charged a prorated amount of the management fee based on the number of days services were provided during the termination month. For example, if there are 30 days in a month and the service was cancelled 15 days into the month, the client will be charged 50% of the monthly management fee. (15 divided by 30 equals 50%) Brindle & Bay Financial Advisors Page 6 ADV Part 2A – 10/5/2026  OTHER SECURITIES COMPENSATION We do not receive any additional securities compensation. The item is not applicable. RETIREMENT ROLLOVER CONFLICTS OF INTEREST When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts of interest with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Item 6 – Performance-Based Fees and Side by Side Management We do not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or provide side by side management. Item 7 – Types of Clients We offer services to individuals and high net worth individuals. We generally require a minimum of $1,000,000 in assets under management to establish an advisory relationship. We may waive this minimum in our discretion based on a client's individual circumstances. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS AND INVESTMENT STRATEGIES When we create a client’s financial plan and manage a client’s portfolio, we start with an asset allocation model. When managing our model portfolios, we use a dynamic weighting strategy. Asset allocation is an investment strategy that aims to balance risk and reward by apportioning a portfolio’s assets according to an individual’s goals, risk tolerance and investment horizon. The asset classes typically include equities, fixed-income, international, and cash and equivalents. The risk associated with asset allocation is that each class has different levels of risk and return, so each will behave differently over time. There is no guarantee that diversification among asset classes will grow a portfolio. Dynamic weighting is a portfolio management strategy that frequently adjusts the mix of asset classes to suit market conditions. Adjustments usually involve reducing positions in the worst- performing asset classes while adding to positions in the best-performing asset classes. There are two main risks or limitations with this strategy. Actively adjusting portfolio allocations to meet changing market conditions takes time and resources. Investment managers need to keep up-to- date with breaking macro- and company-specific news to determine its impact on various asset classes. Additional research analysts may need to be hired to help ensure the correct investment Brindle & Bay Financial Advisors Page 7 ADV Part 2A – 10/5/2026  decisions are made. If most holdings in the portfolio are trending higher, a management strategy that favors buy-and-hold investing, such as constant-weighted asset allocation, may outperform dynamic portfolio due to fewer transaction costs. In some of our model portfolios we purchase securities with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. The risk associated with using a long-term purchase strategy is that it generally assumes the financial markets will go up in the long-term, which may not be the case. There is also the risk that the segment of the market that the client is invested in or perhaps just that client’s investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. We engage Advisor 123 as a third-party service provider to assist us with the development and ongoing evaluation of the investment models we use in managing client accounts. Advisor 123 provides research and analytical support related to model design, tests the models, and provides recommendations regarding model allocations and rebalancing. Advisor 123 does not have discretionary authority over client accounts and does not independently implement investment decisions or execute transactions on behalf of our clients. We retain responsibility for evaluating Advisor 123's recommendations, determining whether and how those recommendations will be implemented, and determining whether the resulting investment strategy is appropriate for each client. We also periodically review Advisor 123 and its services as part of our oversight of third-party service providers. INVESTMENT RISKS All investment programs have certain risks that are borne by the client and investing in securities involves risk of loss that clients should be prepared to bear. While we use investment strategies that are designed to provide appropriate investment diversification, some investments have significantly greater risks than others. Obtaining higher rates of return on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. You should feel free to ask questions about risks you do not understand. We would be pleased to discuss them. RECOMMENDED SECURITIES Several types of securities are used in client accounts including, but not limited to, stocks, bonds, mutual funds, exchange traded funds and money market funds. Some of the risk associated with these securities include: • Credit Risk: This is the risk that an issuer of a bond could suffer an adverse change in financial condition that results in a payment default, security downgrade, or inability to meet a financial obligation. Brindle & Bay Financial Advisors Page 8 ADV Part 2A – 10/5/2026  • Inflation Risk: This is the risk that inflation will undermine the performance of an investment and/or the future purchasing power of a client's assets. • Interest Rate Risk: The chance that bond prices overall will decline because of rising interest rates. • International Investing Risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, as well as regulatory and financial reporting standards, which differ from those of the U.S. • Manager Risk: The chance that the proportions allocated to the various securities will cause the client’s account to underperform relevant to benchmarks or other accounts with a similar investment objective. • Stock Market Risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising stock prices and periods of falling stock prices. 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 each supervised person providing investment advice. We do not have information applicable to this item. Item 10 – Other Financial Industry Activities and Affiliations We are not affiliated with a broker-dealer. We are not affiliated with a futures or commodities broker. OTHER INDUSTRY AFFILIATIONS Our owner, Mr. Davis, has made a personal investment in Altruist Corporation, the parent company of Altruist Financial LLC (“Altruist”), the qualified custodian and broker-dealer we use to hold client accounts and execute client transactions. This investment presents a conflict of interest because Mr. Davis has a financial interest in Altruist and therefore has an incentive to recommend or continue using Altruist for client accounts. We address this conflict by periodically evaluating the services provided by Altruist and the continued appropriateness of our custodial and brokerage relationship with Altruist. Our review includes consideration of factors relevant to the quality of Altruist's custodial and brokerage services, including the quality of execution received for client transactions. Mr. Davis's investment in Altruist Corporation is not considered as a factor favoring the selection or continued use of Altruist. We remain responsible for Brindle & Bay Financial Advisors Page 9 ADV Part 2A – 10/5/2026  determining whether our use of Altruist is consistent with our fiduciary obligations to clients. Clients are encouraged to discuss any concerns regarding this conflict with us. Our owner, Mr. Davis, is managing member and an independent insurance agent of Brindle & Bay Wealth Management, LLC. As part of the financial planning process, Mr. Davis may recommend insurance products to clients, but only when appropriate based on the client’s needs and financial circumstances. This other business activity pays a commission that is separate from the fees described above. This creates a financial incentive to recommend and sell insurance products to clients. However, Mr. Davis attempts to mitigate any conflicts of interest to the best of his ability by placing the clients’ interests ahead of his own, through his fiduciary duty and by informing clients that they are never obligated to purchase any recommended insurance products through him. RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISER Brindle & Bay Financial Advisors has a referral arrangement with Domain Money Advisors, LLC (“Domain”), an SEC-registered investment adviser. Brindle & Bay Financial Advisors is not affiliated with Domain. Additional information regarding this arrangement, including related conflicts of interest, is provided in Item 14 of this Brochure. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CODE OF ETHICS Our Code of Ethics establishes ideals for ethical conduct based upon fundamental principles of openness, integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any client or prospective client upon request. Our Code of Ethics covers all staff, and it describes our high standard of business conduct and fiduciary duty to our clients. The Code of Ethics includes, among other things, provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition on rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons must acknowledge the terms of the Code of Ethics annually or as amended. MATERIAL INTEREST IN SECURITIES We do not have a material interest in any securities. INVESTING IN OR RECOMMENDING THE SAME SECURITIES Our staff is permitted to engage in personal securities transactions. These transactions create potential conflicts of interest if they were to trade in advance in a security that is owned by a client or considered for purchase or sale on behalf of a client. We have adopted policies and procedures that are reasonably designed to effect transactions for the client in a manner consistent with the fiduciary duty owed to each client. Our staff who buys or sells the same Brindle & Bay Financial Advisors Page 10 ADV Part 2A – 10/5/2026  securities bought or sold for a client may do so only if they comply with the firm’s written policies and procedures. Item 12 – Brokerage Practices RECOMMENDATION CRITERIA We generally recommend that clients establish brokerage accounts with Altruist Financial LLC (“Altruist”), a registered broker-dealer and qualified custodian, to maintain custody of client assets and execute securities transactions. We are independently owned and operated and are not affiliated with Altruist. However, as described in Item 10, our owner, Nicolas Davis, has made a personal investment in Altruist Corporation, the parent company of Altruist. This investment creates a conflict of interest in our recommendation and continued use of Altruist. In selecting and periodically evaluating Altruist, we consider the overall quality and scope of the services provided to our clients rather than any single factor. Factors considered may include the quality of trade execution; transaction costs and other charges; financial strength and reputation; access to securities and investment products; account administration and reporting; accuracy and reliability of transaction processing; client service; technology and integration capabilities; and the overall quality of custodial and brokerage services. We are not required to select the broker-dealer offering the lowest commission or transaction cost. Consistent with our duty to seek best execution, we seek to obtain the most favorable overall terms reasonably available under the circumstances, taking into consideration the full range and quality of brokerage services provided. BEST EXECUTION We periodically evaluate the quality of execution Altruist provides for client transactions. Our review considers quantitative and qualitative information, as applicable and reasonably available, including execution prices, transaction costs, speed and quality of execution, order handling, the nature and liquidity of the securities traded, and other factors that may affect the overall quality of execution. We also consider whether alternative broker-dealers or trading arrangements are reasonably available and whether the continued use of Altruist is consistent with our obligation to seek best execution for clients. Our review is conducted at least annually and may also be conducted when circumstances arise that could materially affect the quality of execution or brokerage services received by our clients. Mr. Davis's personal investment in Altruist Corporation is not considered as a factor favoring the selection or continued use of Altruist. We document our best execution review and our determination regarding the continued use of Altruist. Brindle & Bay Financial Advisors Page 11 ADV Part 2A – 10/5/2026  RESEARCH AND OTHER BENEFITS We may receive certain technology, support services, or other economic benefits from Altruist in connection with our institutional relationship with Altruist. These benefits are described in Item 14. The receipt of these benefits creates a potential conflict of interest because they provide an additional incentive for us to recommend or continue using Altruist. We consider this conflict as part of our periodic evaluation of our custodial and brokerage relationship with Altruist and our best execution review. BROKERAGE FOR CLIENT REFERRALS We do not select or recommend Altruist based on client referrals from Altruist, and Altruist does not compensate us for recommending brokerage or custodial services to clients. DIRECTED BROKERAGE We require investment management clients to maintain their accounts with Altruist and do not permit clients to direct us to execute transactions through another broker-dealer. TRADE AGGREGATION We may aggregate or “block” orders for the purchase or sale of the same security for multiple client accounts when we determine that doing so is appropriate and in the best interests of the participating clients. Aggregating orders may facilitate more efficient trade execution and help ensure that participating clients receive equitable treatment. When orders are aggregated, each participating account generally receives the average execution price for the aggregated transaction and bears its proportionate share of any transaction costs. We determine the accounts participating in an aggregated order and the intended allocation before the order is entered. If an aggregated order is only partially filled, securities will generally be allocated among participating accounts on a pro rata or other fair and equitable basis. Proprietary, affiliated, or supervised-person accounts may participate in aggregated transactions but will not receive preferential treatment over client accounts. We seek to allocate aggregated transactions fairly and equitably over time, and no client or group of clients will be systematically favored or disadvantaged. Item 13 – Review of Accounts For our financial planning clients, our owner or investment adviser representatives review and update client’s written financial plan annually. For our investment management clients, we monitor portfolios on an ongoing basis. Our owner, Mr. Davis, conducts formal reviews of portfolios on at least a quarterly basis. We contact clients at least annually to review their financial circumstances. Brindle & Bay Financial Advisors Page 12 ADV Part 2A – 10/5/2026  Additional reviews are conducted periodically depending on market conditions, economic or political events, or due to changes in a client’s financial situation (such as retirement, termination of employment, physical move or inheritance). Financial planning clients have access to their digital financial plan. They also receive a copy of their one-page summary of their goals and priorities. Item 14 – Client Referrals and Other Compensation We maintain an institutional relationship with Altruist whereby they provide certain services (e.g., technology solutions) and benefits to us (“Support Services”). Support Services provided to or on our behalf will not directly benefit client accounts. Support Services received from Altruist does not depend on the number or value of brokerage transactions directed to Altruist. These services are available to all advisers who participate in Altruist’s Advisor Tech Collection program and are not provided in exchange for us directing client trades to Altruist. Therefore, the services and benefits that we receive from Altruist are not considered soft dollar arrangements. The receipt of these benefits creates a potential conflict of interest, as we could have an incentive to recommend you maintain your account with Altruist. However, we strive to recommend the custodian that is most appropriate for you based on your individual needs. Brindle & Bay Financial Advisors has entered into a referral agreement with Domain Money Advisors, LLC (“Domain”), an SEC-registered investment adviser. Under this arrangement, Domain compensates us for referring prospective clients who engage Domain for financial planning services. We receive twenty-five percent (25%) of advisory fees paid by referred clients during the first year of the relationship and twenty-five percent (25%) of advisory fees in each subsequent year that the client remains a client of Domain. This compensation creates a conflict of interest because Brindle & Bay Financial Advisors has a financial incentive to recommend Domain over other advisory firms. Clients do not pay any additional fees as a result of this arrangement. Brindle & Bay Financial Advisors and Domain are not affiliated. Clients referred to Domain will receive a separate written disclosure document describing the referral arrangement, including the compensation to be received, and will be required to provide their written acknowledgment prior to or at the time of entering into an agreement with Domain. Item 15 – Custody All Client funds, securities and account are held at third-party custodians. We do not take possession of a client’s funds, securities or accounts. The custodians will also send at least quarterly account statements. We urge clients to carefully review their account statement and notify us of any discrepancies as soon as possible. Item 16 – Investment Discretion All Portfolio Management clients sign an investment management agreement that contains a limited power of attorney granting us discretionary power over the account. In discretionary Brindle & Bay Financial Advisors Page 13 ADV Part 2A – 10/5/2026  accounts, we will be allowed to place trades, buy or sell securities of any type and in amounts it deems to be appropriate for the account, without first obtaining the client’s consent to each trade. Directions will be given to the account custodian to complete the transaction. Our other services are non-discretionary, which means the client retains full discretion to supervise, manage, and direct his or her assets. We will make recommendation on how the assets should be managed. However, the client will be free to manage the assets with or without our recommendation and all with or without our prior consultation. Item 17 – Voting Client Securities We do not vote proxy votes for any client. All proxy materials are mailed or emailed directly to the client from the custodian. Any proxy materials received by us will be forwarded to clients for response and voting. In the event the client has a question about a proxy solicitation, the client should feel free to contact us. Additionally, we do not file class action settlement claims involving securities on a client’s behalf. Item 18 – Financial Information We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to provide a balance sheet. We are required in this Item to provide you with certain financial information or disclosures about our financial condition if we have a financial commitment that impairs our ability to service you. We do not have a financial commitment that impairs our ability to service our clients. We have not been the subject of a bankruptcy proceeding. Brindle & Bay Financial Advisors Page 14 ADV Part 2A – 10/5/2026