CARDINAL ADVISERS LLC

Item 1 – Cover Page CARDINAL ADVISERS LLC 6250 SW 133rd St. Miami, FL 33156 United States of America Telephone: 786-216-7547 www.cadfl.com Date of Brochure: January 15, 2026 This Form ADV Part 2A Brochure (“Brochure provides information about the qualifications and business practices of Cardinal Advisers LLC (hereinafter referred to as “Cardinal Advisers,” “The Firm,” or “we”). If you have any questions about the content of this Brochure, please contact the Firm’s Chief Compliance Officer at the telephone number provided above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Registration as an investment adviser does not imply any level of skill or training. You should not make a determination to hire or retain any adviser based solely on the fact that the adviser is registered. Additional information about the Firm is available on the SEC’s Investment Adviser Public Disclosure web site at www.adviserinfo.sec.gov.  Item 2 – Material Changes In this section, we are required to summarize the material changes that were made since the previously issued Brochure. This is Cardinal Advisers LLC’s annual updating amendment. Since the last Form ADV filing in November 2025, the Firm obtained SEC-registered investment adviser registration and terminated its Florida state registered investment adviser registration. We will provide you with a new Brochure whenever there are material changes to the information contained in this Brochure. You may obtain a copy of our current Brochure at any time by contacting the Firm’s Chief Compliance Officer at the telephone number listed on the cover page of this Brochure. You may also download the most recent version of the Brochure from the SEC’s Investment Advisor Public Disclosure website at www.adviserinfo.sec.gov. 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................. 1 Item 2 – Material Changes .................................................................................................................................. 2 Item 4 – Advisory Business .................................................................................................................................. 4 A. Business Commencement Date ................................................................................................................ 4 B. Ownership ................................................................................................................................................. 4 C. Services ..................................................................................................................................................... 4 D. Assets Under Management ...................................................................................................................... 5 Item 5 – Fees and Compensation ........................................................................................................................ 5 A. Fees ........................................................................................................................................................... 5 B. Termination of Service .............................................................................................................................. 7 C. Other Fees ................................................................................................................................................. 7 D. Broker/Dealer Charges .............................................................................................................................. 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. Investment Strategies ............................................................................................................................... 9 C. Risks ........................................................................................................................................................ 10 Item 9 – Disciplinary Information ...................................................................................................................... 14 Item 10 – Other Financial Industry Activities and Affiliations ........................................................................... 14 Item 11 – Code of Ethics .................................................................................................................................... 15 Item 12 – Brokerage Practices ........................................................................................................................... 15 Item 13 – Review of Accounts ........................................................................................................................... 17 Item 14 – Client Referrals and Other Compensation ........................................................................................ 18 A. Referral Fees Paid ................................................................................................................................... 18 B. Referral Fees Received ............................................................................................................................ 18 Item 15 – Custody .............................................................................................................................................. 18 Item 16 – Investment Discretion ....................................................................................................................... 19 Item 17 – Voting Client Securities ..................................................................................................................... 19 Item 18 – Financial Information ........................................................................................................................ 19 3  Item 4 – Advisory Business A. Business Commencement Date Cardinal Advisers was organized in the State of Florida in May of 2016. B. Ownership Mr. Zaheer Edoo is the sole (100%) owner of Cardinal Advisers LLC. C. Services DISCRETIONARY ACCOUNTS. The Firm provides personalized discretionary investment management services to its clients. Clients are asked to provide the Firm with certain information regarding their current financial position and holdings, investment objectives, risk tolerance, liquidity needs, and time horizon. Based on the information supplied by the client, the Firm constructs an investment allocation and policy it believes is suitable for that client. FINANCIAL PLANNING SERVICES. The Firm offers financial planning services to clients on a one-time, non-discretionary basis for a fixed or an hourly fee. Clients are asked to provide the Firm with certain information regarding their current financial holdings, investment objectives, risk tolerance, liquidity needs, and time horizon. Based on the information supplied by the client, the Firm will recommend an investment strategy, an allocation mix, or changes to the client's existing portfolio that the Firm believes are suitable for that client. Cardinal does not have an ongoing responsibility to make recommendations to the client. The Firm does not have the responsibility to arrange any securities transaction but may arrange one or more transactions upon the client's instruction. Assets in these types of non-discretionary accounts are not included in the assets under management calculation below. SUB-ADVISORY SERVICES. The Firm provides sub-advisory services to unaffiliated registered investment advisors. The fees for these services are listed under Item 5, Fees and Compensation. Our sub-advisory services include portfolio design and implementation based on the sub-advised clients’ financial goals, investment objectives, and risk tolerance. The unaffiliated investment advisors are responsible for the client relationship and for ensuring that the sub- advised client’s updated client suitability information is made available to Cardinal. Interests in publicly listed partnerships, investing in real estate and/or oil & gas interests INVESTMENT PRODUCT TYPES. Generally, the Firm’s investment advice is confined to the following universe of securities and products:  Exchange-listed securities  Exchange Traded Funds (“ETFs”), including Crypto ETFs  Securities traded over-the-counter  Securities issued by foreign issuers, including foreign sovereign debt instruments  Corporate debt securities  U.S. government securities  Municipal securities  Mutual funds (foreign and domestic)  Options contracts on securities and/or ETFs   Private Equity and Private Credit 4  OTHER SERVICES. The Firm assists in the formation of and acts as an agent to maintain offshore personal holding companies, corporations and trust structures on behalf of our international clients. These services are offered as an accommodation to our clients and do not represent the Firm's primary business. LEGAL AND TAX ADVICE. The Firm does not render legal or tax advice. D. Assets Under Management As of December 31, 2025, the Firm is managing approximately USD $118,539,851 million in client assets on a discretionary basis. Item 5 – Fees and Compensation A. Fees DISCRETIONARY ACCOUNTS. Generally, the Firm charges fees in accordance with the following fee schedule: AUM (USD) Up to $100,000 $100,000 - $999,999 $1,000,000 and Over Annualized Fee USD $1,000 fixed fee per annum 1.00% 0.80% "AUM" means the assets under the management of the Firm for a particular client or client account. The fees listed in the schedule above are annualized figures. Fees are generally charged quarterly and in arrears. The fee is based on the daily average balance provided by the client’s custodians, for all net assets held in the client's account during the period and includes cash balances in client accounts. The custodian or other independent third party determines account valuations. Fees may be adjusted pro rata based on the number of calendar days for which the advisory agreement was in effect. Additional deposits to the account are subject to the same prorata fee procedures. The client will generally be charged a pro rata fee if the client's service is terminated on a day other than the last business day of the semiannual period. In that event, the pro rata fee will be due and payable upon termination of the service. The Firm may adjust the advisory fee schedule upon thirty (30) days' prior written notice to the client. In certain instances, fees are negotiable. The client's account will be directly debited for the above-mentioned fees. When the client's account is debited, the Firm may collect its advisory fees from available cash in the client's account, the amount of any contribution or transfer, or by liquidating the client's assets held in the client's account, in an amount equal to the fees due. The custodian account statement will reflect the fee deduction amount. We request that clients carefully review their custodian statements and inform us of any discrepancies. An asset-based fee may cost more than a transaction-based fee, but clients may prefer an asset- based fee if they want continuing advice or for the investment adviser to make investment decisions on their behalf. Although Cardinal believes the charges and fees offered are competitive, comparable services and charges may be available from other investment advisers at a lower or higher cost. 5  When appropriate, Cardinal may recommend using margin and/or option transactions. As these investment strategies involve a degree of additional risk, they are recommended only when consistent with the client’s objectives and risk tolerance. The use of margin also results in interest charges in addition to all other fees and expenses associated with the management of the account. Although account statements for margined accounts may reflect a negative amount, our advisory fee is based on the account’s net asset value. This poses a conflict of interest because Cardinal benefits by receiving a higher fee based on the account’s absolute market value. PLATFORM FEES. The Firm currently utilizes two (2) primary brokers to custody client assets, Insigneo Securities LLC (“Insigneo”), which offers custodial services through Pershing LLC, and Interactive Brokers LLC (“IBKR”). A broker may charge a Platform Fee to service client accounts. The Platform Fee is part of a broker’s compensation and is in addition to what we charge. This fee is NOT shared with Cardinal Advisers LLC. The broker’s Platform Fee may include brokerage commissions, transaction fees, sales loads, sales charges, third-party management fees, administrative fees, account maintenance fees, wire or electronic fund transfer fees, transfer taxes, and other fees charged by the broker or dealer selected for execution of securities transactions in the Client’s advisory accounts. The Platform Fee may be amended at any time by Insigneo or by IBKR. Please refer to your Insigneo, IBKR, or custodian institution’s account brokerage agreement and fee disclosures for updated information regarding the Platform Fees and other fees and expenses charged by the broker or custodian that houses your account. FLAT FEES. In certain circumstances, the Firm offers advisory services for a flat or fixed fee. Fixed fees are generally reserved for very small portfolios and depend on the level and complexity of the services involved. Such fees will be set forth in the Fee Schedule attached to the client’s financial planning agreement. FINANCIAL PLANNING SERVICES. The Firm offers financial planning services on an hourly or fixed-fee basis. Generally, the hourly fee is USD $300. In certain instances, hourly fees are negotiable. Fixed fees depend on the complexity of the plan and will be set forth in the Fee Schedule attached to the client’s financial planning agreement. Fifty percent (50%) of the estimated fees are due upon the signing of the financial planning agreement. The remaining fees are due upon delivery of the advisory report to the client or upon the close of the meeting in which the advisory recommendations are presented to the client, whichever occurs earlier. SUB-ADVISORY SERVICES FEES. Fees for sub-advisory services to unaffiliated investment advisors are generally based upon 50% of the total assets under management, or as agreed to with the unaffiliated investment advisor. Clients of unaffiliated investment advisors should consult with their advisor and review the unaffiliated investment adviser’s Form ADV and other disclosure documents to understand their billing policies and whether Cardinal’s sub-advisory services fees are included in the fees they pay to the unaffiliated investment adviser. FORMATION & RENEWAL OF COMPANIES. Cardinal may assist clients with the formation of offshore companies to house their portfolio investments. The Firm generally charges a professional fee of USD $1,000 to perform administrative work in connection with preparing and submitting documents to form an offshore company. Cardinal charges USD $500 per annum for administrative work to renew the company’s registration and fulfill its annual corporate requirements. 6  B. Termination of Service DISCRETIONARY ACCOUNTS. Upon written notice to the Firm, within five (5) business days of entering into an agreement with the Firm, the client will have the right of termination without penalty or payment of fees. The Firm will refund any payments made. Thereafter, either the Firm or the client may terminate the agreement upon thirty (30) days' written notice to the other party. FINANCIAL PLANNING SERVICES. Prior to the delivery of the advisory report, the client may terminate the agreement upon written notice to the Firm. Upon termination, the Firm is entitled to compensation for time expended on the consultation and/or preparation of the advisory report, and any unearned fees already paid will be refunded to the client. The agreement for financial planning is limited in duration and generally terminates automatically upon the provision of the advisory report or recommendations to the client. C. Other Fees In addition to the Firm’s advisory fees, other fees may apply. Brokerage commissions, transaction fees, sales loads, sales charges, management fees, administrative fees, account maintenance fees, transfer taxes, wire transfer fees, electronic fund fees, and other fees may be charged by the broker or dealer selected for execution of the securities transactions in the advisory accounts, by the custodian, and/or by the distributor, issuer or fund issuing the securities purchased and sold within the advisory accounts. The client is solely responsible for paying all such charges. In addition to Cardinal’s advisory fee, each mutual fund or ETF in which a client's assets may be invested also charges its own management fees and other expenses. The specific fees and expenses are described in the respective fund’s prospectus. Depending on the fund, a client may be able to invest directly in the shares issued by a mutual fund with or without incurring any sales or advisory fees. Mutual fund companies generally offer multiple share classes of the same fund. Share classes are described in the mutual fund's prospectus. Each share class charges different fees and expenses. Depending on the share class selected, fees and internal expenses charges may be higher or lower. Certain funds do not charge transaction fees but incur higher internal expenses. Selecting funds that charge higher fees and expenses may adversely impact an account’s long‐term performance. Cardinal’s policy is to recommend that clients invest in the lowest-cost share class available, based on the client’s individual situation. Cardinal generally recommends advisor- or institutional-share classes, which typically have the lowest expense ratios and are more beneficial than other share classes. Advisor or institutional share classes are generally available to investors in qualified fee‐based advisor programs or accounts that meet certain minimum investment requirements. When deemed appropriate, we may recommend that a client who transfers in mutual fund holdings liquidate their existing holdings, which could result in tax consequences, contingent deferred sales charges, or other redemption fees. Clients are encouraged to review the fees charged by the funds and our advisory fees to fully understand the total amount of fees to be paid. Please refer to the mutual fund's prospectus for additional information regarding a particular fund’s fees and expenses. 7  D. Broker/Dealer Charges Item 12 further describes the factors the Firm considers when recommending broker-dealers for client transactions and when determining the reasonableness of their compensation (e.g., commissions). Item 6 – Performance-Based Fees and Side-By-Side Management The Firm does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of a client's assets). Item 7 – Types of Clients The Firm provides advisory services to individuals, including high-net-worth individuals, trusts, and foreign and domestic entities, including unaffiliated registered investment advisers. When subscribing to the Firm’s advisory services, the minimum account value is generally USD $100,000. In some special cases, such as when the client has a longstanding relationship with the Firm’s management, account minimums may be negotiated or waived at the Firm’s discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis When formulating investment advice, the Firm may utilize any one or more of the following security analysis methods:  Fundamental Analysis. Fundamental analysis is a method of attempting to measure a security’s underlying value and potential for future growth (its intrinsic value) by examining economic, financial and other qualitative and quantitative factors directly related to the issuer/company as well as company-specific factors (like financial condition, management, and competition). The adviser compares the intrinsic value with the security's current price, with the aim of determining what position to take with the security (i.e., buy, sell or hold).  Technical Analysis. Technical analysis is a method of evaluating securities by analyzing demand and supply based on recent trading volume, price studies, and the buying and selling behavior of investors. Technical analysis assumes that market psychology influences trading, enabling the prediction of when a stock will rise or fall. Technical analysts do not attempt to measure a security's intrinsic value but instead use charts or computer programs to identify and project price trends.  Charting. Charting is a method by which an adviser analyzes trends in a security’s price, insider sales, short sales, and/or trading volume in an attempt to ascertain major market downturns, upturns, and trend reversals.  Cyclical Analysis. Cyclical analysis examines business cycles to identify favorable conditions for buying and/or selling a particular security. The Firm does not represent, warrant, or imply that any analysis method employed by the Firm can or will successfully identify market tops or bottoms. No analysis method has been proven to insulate clients from losses due to market fluctuations, corrections or declines. 8  B. Investment Strategies We will generally use the following portfolio management strategies: Asset Allocation - Asset allocation is a strategy that aims to balance risk and reward by distributing your investments among different asset classes such as stocks, bonds, cash, etc. based on the client’s risk tolerance, time horizon, and financial goals. The concept of asset allocation, or spreading investments across several asset classes (e.g., domestic vs. foreign stocks; large-cap vs. small-cap stocks; corporate bonds vs. government debt instruments), plays a prominent role in executing an investment strategy. Asset allocation seeks to diversify assets to reduce the risk of investing a significant portion of a client’s portfolio in a single asset class. We believe that risk reduction is a key element to long-term investment success. Diversification – Diversification is a risk management strategy that involves allocating the client’s investments across a variety of assets to reduce the impact of any single investment's performance on the overall portfolio. Rebalancing – Rebalancing is the process of realigning the weightings of portfolio assets to maintain the original target asset allocation. Rebalancing ensures that a portfolio stays aligned with the client’s initial investment strategy and risk tolerance. Investment strategies may include long-term and short-term purchases, short selling, frequent trading, buying on margin, and option writing. The strategies employed will depend on the client's individual needs and risk tolerance. A short description of each of these strategies follows:  Buy and Hold. Generally, a long-term purchase is the purchase of a security or investment product with a view to holding it for more than one year. Trade commissions are reduced by buying and selling less often and taxes are often reduced or deferred by holding positions longer. We typically will follow a buy-and-hold strategy when pursuing a value investment strategy or an emerging markets investment strategy. This is our primary strategy for debt instruments.  A value investment strategy involves recommending securities we believe are priced below their intrinsic value but remain fundamentally sound.  An emerging markets strategy involves investing in stocks or bonds issued by companies and government entities in developing countries, such as in Latin America, Eastern Europe, Africa and Asia. Typically, there is a medium- to long-term holding period and there can be high volatility.  Short-term purchases. A short-term purchase is the purchase of a security or investment product with the intent to sell it within one year of purchase.  Short-term trading. Short-term trading focuses on opportunistic trades – holding investments for only brief periods. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes.  Short sales. Short selling is a technique used to profit from a stock’s decline in price. Short selling can translate into high portfolio volatility.  Margin Transactions. An investor may buy securities with money borrowed from the broker/dealer. The borrower will be required to pay interest on the loan. 9   Option writing. Investors can sell options in order to obtain additional income from premiums paid by the option buyer. The potential upside of this strategy is limited because the most the investor can earn is the option premium. Although Cardinal will seek to implement strategies to minimize potential losses, there can be no assurance that these strategies will be successful, particularly in the short term, and clients may lose all or a substantial portion of their assets. C. Risks 1. General Risks. Investing in securities involves risk of loss that clients should be prepared to bear. Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment or investment strategy will either be suitable or profitable for a client's investment portfolio. Past performance is not indicative of future results. A client should not assume that the future performance of any specific investment, investment strategy, or product will be profitable or equal to past or current performance levels. The Firm cannot assure that any client's investment objectives will be realized. 2. Special Risks. While investing in any security involves risk, investing in some types of securities carries special risks. A summary of the special risks associated with some types of securities we may recommend is provided below. Please note that the following summaries are general in nature and do not include an explanation of all risks associated with a given security type. We request that you contact your investment adviser representative with any questions. a. Bonds. Bonds are subject to credit risk, which is the risk of default associated with the issuer. Bonds are also subject to interest rate risk or the risk that changes in interest rates during the term of the bond might affect the market value of the bond prior to the call or maturity date. Investors should also consider inflation risk, which is the risk that the yield to call or maturity will not exceed the rate of inflation over the period of the investment. b. Foreign-Issued Securities. Debt and equity investments associated with foreign countries may involve increased volatility and risk due to, without limitation:  Political Risk. Many foreign countries are undergoing, or have undergone in recent years, significant political change that has affected government policy, including changes in the regulation of industry, trade, financial markets, and foreign and domestic investment. The relative instability of these political systems leaves these countries more vulnerable to economic hardship, public unrest, or widespread dissatisfaction with reform, political or diplomatic changes, social instability, or changes in government policies. For investors, the results may include confiscatory taxation, exchange controls, compulsory reacquisition, nationalization, or expropriation of foreign-owned assets without adequate compensation, or the restructuring of certain industries in ways that could adversely affect investments in those sectors.  Sovereign Risk. Strikes, the imposition of exchange controls, or declarations of war may prevent or impede repayment of funds due from a particular country.  Economic Risk. The economies of these countries may be more vulnerable to rising interest rates and inflation. Investments may be negatively affected by economic 10  growth rates, corporate profits, domestic and international flows of funds, external and sovereign debt, dependence on international trade, and sensitivity to world commodity prices. Additionally, a change in tax regime may result in the sudden imposition of arbitrary or additional taxes.  Currency Risk. The weakening of a country's currency relative to the U.S. dollar or to other benchmark currencies will negatively affect the dollar value of an instrument denominated in that currency.  Credit Risk. Issuers and obligors of sovereign and corporate debt may be unable to make timely coupon or principal payments, thereby causing the underlying debt or loan to enter into default.  Liquidity Risk. Natural disasters, as well as economic, social, and political developments in a country, may cause a decrease in the liquidity of investments related to that country, making it difficult to sell quickly and/or subjecting the seller to substantial price discounts. In addition, for debt investments (i.e. bonds), bonds are often purchased in a block and then broken up among various client accounts. In many instances, a client may end up holding less than the minimum tradable block. This exposes the client to illiquidity risk should the position subsequently need to be sold. c. Emerging Market Securities. Investments and transactions in products linked to issuers and obligors incorporated, based, or principally engaged in business in emerging market countries carry increased risk and volatility. In addition to the political, sovereign, economic, currency, credit, and liquidity risks described above, emerging market securities can be subject to the following risks:  Market Risk. The financial markets can lack transparency, liquidity, and efficiency.  Regulatory Risk. There may be less government supervision and regulation of business. The supervision in place may be subject to manipulation or control. Disclosure and reporting requirements may be minimal or non-existent.   Legal Risk. The process of legal reform may not keep pace with market developments, leading to uncertainty. Legislation to safeguard the rights of private ownership may not yet be in place. Settlement and Clearing Risk. The registration, recordkeeping, and transfer of instruments may be carried out manually, which may cause delays. d. Mutual Funds. Most mutual funds fall into one of three main categories - money market funds, bond funds (also called "fixed income" funds), and stock funds (also called "equity" funds). Generally, the higher the potential return, the higher the risk of loss. A fund's investment objective and its holdings are influential factors in determining risk. Past performance is not a reliable indicator of future performance. Reading the prospectus will help you to understand the risks associated with that particular fund. Different mutual fund categories have inherently different risk characteristics. For example, a bond fund faces credit risk, interest rate risk, and prepayment risk. Bond values are inversely related to interest rates. If interest rates go up, bond values will go down and vice versa. 11  Overall, "market risk" poses the greatest risk to investors in stock funds. Stock prices can fluctuate for a broad range of reasons - such as the overall strength of the economy or demand for particular products or services. A sector stock fund (which invests in a single industry, such as telecommunications) is at risk that its price will decline due to developments in its industry. A stock fund that invests across many industries is more sheltered from this risk. For most funds, investors must pay sales charges, annual fees, and other expenses regardless of how the fund performs. And, depending on the timing of their investment, investors may also have to pay taxes on any capital gains distribution they receive. e. Exchange-traded Funds (“ETFs”). An ETF is a type of investment company (usually, an open-end fund or unit investment trust) containing a basket of stocks. Typically, the objective of an ETF is to achieve returns similar to a particular market index, including sector indexes. An ETF is similar to an index fund in that it primarily invests in the securities of companies in a selected market. Unlike traditional mutual funds, which can only be redeemed at the end of a trading day, ETFs trade throughout the day on an exchange. Like stock mutual funds, the prices of the underlying securities and the overall market may affect ETF prices. Similarly, factors affecting a particular industry segment may also affect ETFs that track that sector. ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because (i) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark, (ii) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable, and (iii) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Leveraged ETFs. Leveraged ETFs seek to deliver multiples of the performance of the index or benchmark they track. Some ETFs are "inverse" or "short" funds, meaning they seek to deliver the opposite performance of the index or benchmark they track. Most leveraged and inverse ETFs "reset" daily, meaning they are designed to achieve their stated objectives each day. Due to compounding, their performance over longer periods can differ significantly from the performance (or inverse) of their underlying index or benchmark during the same period. This effect is magnified by leverage. Therefore, inverse and leveraged ETFs that are reset daily typically are unsuitable for investors who plan to hold them for longer than one trading session. This is particularly true in volatile markets. trade on traditional market exchanges rather Crypto ETFs. Crypto ETFs are ETFs that track the value of Bitcoin (or other cryptocurrencies) and than on cryptocurrency exchanges. There are special considerations associated with Crypto ETFs. It is important to understand that crypto assets were designed as currencies and not primarily as investment assets. Crypto ETFs are highly speculative and volatile. Some Crypto ETFs directly hold physical Bitcoins, Ethereum, or other cryptocurrencies. Others attempt to replicate the assets synthetically through the use of derivatives. Different structures will yield different replication results. Price movements in the coin will not always be exactly reflected in the Crypto ETF’s price. It is also important to understand that ETFs incur their own fees that investors would not incur if they invested 12  directly in Bitcoin. Fees for Crypto ETFs can be high. Additionally, if you own Bitcoin or other cryptocurrencies directly, you can use them just like a regular currency to buy products or services or make payments. You may also benefit from any increase in value relative to your local currency. When you buy a Crypto ETF, however, you cannot use the asset to make (or receive) payments. Instead, you can only benefit if there is a positive price change. f. Municipal Securities. Credit risk is the primary risk associated with municipal securities. Different types of bonds are secured by various types of repayment sources. General obligation (“G.O.”) bonds are backed by the full faith and credit and taxing power of the issuer. With revenue bonds, the interest and principal are dependent upon the revenues paid by users of a facility or service, or other dedicated revenues, including special tax revenues. The probability of repayment as promised is often determined by an independent reviewer, or “rating agency.” An investor might also consider that consumer spending that provides the funding or income stream for revenue bond issuers may be more vulnerable to changes in consumer tastes or a general economic downturn compared to G.O. bonds. g. Private Equity and Private Credit Private equity and private credit investments carry significant risks due to their illiquid, opaque, and leveraged nature. These include  Opaque Structures: Both asset classes operate with limited transparency and  regulatory oversight, complicating risk assessment. Illiquidity: Private equity capital is typically locked up for 5–10 years, limiting redemptions and exit flexibility. Private credit loans lack active secondary markets, making exits difficult and sales costly.  Valuation & Transparency: Infrequent, subjective valuations can obscure losses and market value, especially during downturns. Opaque structures and non-standard contracts can hide risks until stressed periods.  Spillover Risk: Losses in large or retail-focused funds can trigger broader credit tightening or markdowns.  Deteriorating Standards: Rising competition and pressure to deploy capital may weaken underwriting and covenants, increasing credit loss severity in downturns. Private Equity investments carry market, fund and operational risks.  Market Risks: Exposure to equity markets, sector/geographic concentrations, FX, and interest rates.  Funding Risk: Investors may struggle to meet capital calls, forcing asset sales under duress.  Operational Risks: Weak governance or processes may lead to losses without robust oversight. Private Credit investments face additional borrower-specific risks:  Credit Quality: Loans often go to smaller, riskier firms, increasing default risk in downturns. 13   Leverage Risk: Multiple layers of leverage (borrowers, funds, investors) amplify losses during stress.  Redemption Risk: Long lockups generally limit redemptions, but growth in semiliquid retail funds could create run risks. Investors should closely monitor regulatory changes, capital flows, and portfolio exposures to mitigate these risks in private markets. There may be other circumstances not described here that could adversely affect a client’s investment and prevent the portfolio from reaching its objective. Prior to entering into an investment advisory agreement with us, you should carefully consider: (i) committing to management only those assets that you believe will not be needed for current purposes and that can be invested on a long-term basis; (ii) that volatility from investing in the market can occur; and (iii) that, over time, the value of your portfolio may fluctuate and may, at any time, be worth more or less than the amount originally invested. 3. Cybersecurity Risk. Cardinal uses electronic communication networks and media to maintain information about its clients and its business. This creates the potential for cybersecurity incidents or cyberattacks that may result in the inadvertent disclosure of confidential sensitive information to unintended parties, unauthorized access to it, or operational disruptions by malicious hackers. Cardinal has in place policies and procedures regarding information technology security, maintains technical and physical safeguards and takes other reasonable precautions to safeguard the confidentiality of sensitive information and internal data. However, despite reasonable precautions, the risk of cybersecurity incidents remains. If such an event were to occur, Cardinal will promptly notify the affected parties and take all necessary appropriate actions. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding certain legal or disciplinary events related to the adviser or the adviser’s management. Neither the Firm nor its personnel has been subject to any such legal or disciplinary events. Item 10 – Other Financial Industry Activities and Affiliations A. Neither the Firm nor any management person of the Firm is registered or has an application pending to register as a broker/dealer or a registered representative of a broker/dealer. B. Neither the Firm nor any management person of the Firm is registered or has an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of any of the foregoing entities. C. Neither the Firm, nor any management person of the Firm, has any arrangements that are material to its business with any related person. D. We do not recommend or select other investment advisers for our clients. 14  Item 11 – Code of Ethics Securities industry regulations require that advisory firms provide their clients with a general description of the advisory firm's Code of Ethics. The Firm has adopted a Code of Ethics that sets forth its governing ethical standards and principles. It also describes the Firm’s policies regarding the following: the protection of confidential information, including the client's nonpublic personal information; the review of the personal securities accounts of certain personnel of the Firm for evidence of manipulative trading, trading ahead of clients, and insider trading; trading restrictions; training of personnel; and recordkeeping. All supervised persons at the Firm must acknowledge the Code of Ethics upon hire and as amended. Subject to satisfying the Firm’s policies and applicable laws, Firm personnel may trade for their own accounts in securities that are recommended to and/or purchased for the Firm’s clients. The Code of Ethics is designed to permit personnel to invest for their own accounts while assuring that their personal transaction activity does not interfere with making decisions in the best interest of advisory clients or implementing those decisions. Neither the Firm nor any associated person of the Firm who (a) has access to nonpublic information regarding clients' securities transactions, (b) is involved in making securities recommendations to clients, or (c) has access to securities recommendations that are not public (collectively, the "Access Persons") is permitted to trade in or engage in a securities transaction to his or her advantage over that of a client. Because the Code of Ethics permits employees to invest in the same securities as clients, there is a possibility that employees might benefit from a client's market activity in a security held by an employee. Employee trading is monitored by the Firm’s Chief Compliance Officer in an effort to prevent conflicts of interest between the Firm and its clients. The Code of Ethics includes provisions relating to: • Reporting of personal securities holdings and transactions • Reporting of gifts and business entertainment • Preclearance of employees’ participation in certain investments, such as initial public offerings (“IPOs”) and private offerings. • Prohibitions on engaging in fraudulent, deceptive, or manipulative practices, including trading ahead of client orders and insider trading. Certain employee and employee affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with the Firm’s obligation of best execution. In such circumstances, all persons participating in the aggregated order will receive an average share price, with all other transaction costs shared on a pro-rata basis. Our clients or prospective clients may request a copy of the Firm's Code of Ethics by contacting the Chief Compliance Officer at the address or telephone number specified on the cover page. Item 12 – Brokerage Practices Best Execution Cardinal has an obligation to seek “best execution” for client transactions. The SEC defines best execution as the “best qualitative execution” not necessarily the lowest possible execution cost. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the 15  transaction represents the best qualitative execution, taking into consideration the full range of the executing broker’s services, The Firm typically evaluates the following factors when recommending a broker/dealer to a client: • Execution ability, including without limitation: • Trading experience in markets/securities needed • Quality of trading • Clearance and settlement efficiency and accuracy • Accuracy and timeliness of order execution • Costs, including commission rates, ticket charges, other service charges, and the means to correct errors in an acceptable manner • Customer service, including responsiveness to the Firm • Commitment to technology and security of confidential information • Financial strength of the broker/dealer and/or its clearing firm • Reputation and integrity of the broker/dealer and/or its clearing firm We will generally use Insigneo and IBKR to execute client trades. Cardinal will generally not negotiate commissions on behalf of its clients on a trade-by-trade basis, the executing broker or custodian will generally determine those costs. Although executing brokers are subject to best execution obligations and will generally seek competitive commission rates, they are not obligated to choose the broker offering the lowest available commission rate if, in their reasonable judgment, a higher commission may be justified by the services provided by the broker, or by other factors such as those described above. Clients may pay commissions higher than those obtainable from other brokers for the same services rendered by Insigneo, IBKR or any broker/dealer recommended to the client by the Firm. Cardinal believes that Insigneo and IBKR’s fees and other charges and commissions costs are reasonable in relation to the value of services provided, and consistent with its best execution obligations. As part of its fiduciary duty, Cardinal will periodically evaluate the quality of brokerage services received and the quality and cost of services available from alternative brokers or venues. Cardinal receives certain benefits from Insigneo and IBKR. These include custody, clearing, and reporting services, online access for clients, as well as access to an institutional trading desk, and access to a wide range of investment products and services that assist the company in monitoring and/or servicing client accounts. These services may also include pricing information and market data, marketing support, computer hardware and/or software, performance reporting, financial planning, contact management systems, third- party research, publications, access to educational conferences, roundtables, and webinars, practice management resources, access to consultants and other third-party service providers who provide a wide array of business-related services and technology with whom we may contract directly, or other benefits useful to us in providing investment advisory services to clients. The receipt of these economic benefits creates a conflict of interest. It may serve as an incentive for us to recommend Insigneo, or IBKR, and to increase assets at one of these custodians in order to decrease our expenses and receive such benefits. We manage this conflict through disclosure, so that our clients can 16  make an informed decision, and through policies and procedures that require us to always act in the client’s best interests. Soft Dollars We do not receive fees or referrals from broker-dealers or other financial intermediaries in exchange for directing client trades to them. Although Cardinal has not entered into third-party soft-dollar arrangements with any external brokers, the Firm’s receipt of research from the client’s custodian’s brokers or financial intermediaries may be deemed to be soft dollars. To the extent Cardinal receives research, it will be used to benefit all clients. Directed Brokerage If a client asks us to direct transaction(s) to a specific broker or brokers for execution, we may be unable to achieve the most favorable execution. This can result in additional costs for the client. Aggregation of Client Trades When deemed appropriate, we will aggregate or combine client trade orders for the same securities. In an aggregated trade, all participants will receive an average price. If a partial execution is obtained, Cardinal will generally allocate shares on a pro rata basis, or in a manner that is equitable to the clients involved. The Firm will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro-rata basis. Any exceptions must be approved and documented by the Chief Compliance Officer. Allocation of Investment Opportunities From time to time, two or more accounts may seek to invest in the same securities or pursue a similar strategy. In such cases, Cardinal will ensure that allocations are equitable and, over time, one account or group of accounts is not favored or preferred over another account or group of accounts. As a fiduciary, we must, at all times, act in the best interest of all our clients. Principal and Cross Trades The firm does not engage in principal trades or effect cross transactions for client accounts. Trade Errors Cardinal’s trade error policy is to restore the client’s account to the original position through a trade correction, trade cancellation, or adjustment so that clients are not adversely impacted by trade errors. Item 13 – Review of Accounts Accounts are reviewed at least quarterly for consistency with the client's investment objectives, risk tolerance, and financial needs. They may be reviewed more frequently when warranted by market, economic conditions, or whenever there is a significant cash deposit to or withdrawal from the account, or a change in the client’s personal circumstances. The Investment Adviser Representative will review and confirm the client’s investment objectives and selected investment profile at least annually. Clients are reminded to promptly notify us if there are material changes to their financial situation or investment objectives, as this will affect the management of their account. 17  The executing broker-dealer (s) and/or custodian (s) who maintain the client's account (s) will notify the client of any account activity by delivering a trade confirmation of the transaction to the client. The executing broker/dealer(s) or the custodian(s) will also furnish the client with a monthly or quarterly account activity and position statement. Item 14 – Client Referrals and Other Compensation A. Referral Fees Paid The Firm may pay referral fees to persons or entities for the referral or introduction of advisory clients to the Firm. Fee arrangements are fully disclosed to referred clients. There is no differential in the fees charged to the client by the Firm attributable to the arrangement between the referring party and the Firm. In other words, the Firm will not charge any fees to a client referred by another party other than the fees typically charged to other clients. At present, the Firm has no referral fee arrangements in place and is not paying any referral fees, but may enter into such agreements at any time, consistent with SEC Rule 206(4)-1. B. Referral Fees Received The Firm does not receive and does not accept referral fees from other licensed independent investment advisors, brokers, or wealth managers for the referral or introduction of advisory clients. Item 15 – Custody Cardinal’s limited ability to instruct the client’s custodian to deduct advisory fees from client accounts may result in the firm being deemed to exercise “custody” over client assets. We do not accept physical custody of the client’s funds or securities or otherwise engage in activities that would cause the firm to be subject to the Custody Rule. Client’s cash and securities are maintained at Qualified Custodian(s), as defined in the Custody Rule. Clients should receive, on at least a quarterly basis, statements from the broker/dealer, bank or other qualified custodian that holds and maintains the client’s investment assets. The custodian(s)’ also offer clients online access to their accounts. The custodian account statements will show all account activity and transactions during the period, including beginning and ending balances, current values and holdings and the amounts deducted from the client’s account for payment of our advisory fees. We encourage clients to carefully review the custodian account statements and promptly notify us of any discrepancies or errors. Client Reports We will also provide clients with periodic Client Reports. Client Reports will typically include information about the account’s holdings as of the end of the period, the account’s performance and percentage change in asset levels between the beginning and end of the reporting period and will reflect deposits or withdrawals and other important information. In addition, the Firm will provide each client with an annual performance and appraisal report, which includes all management fees charged. Our reports may differ from custodial statements due to accounting procedures, reporting dates, or valuation methodologies for certain securities. Any benchmarks shown in Client Reports are presented for informational purposes only and do not constitute a promise or guarantee that an account will meet or exceed those benchmarks. The custodian statements are the accounts’ only official records. We 18  urge to compare the information on the account statements to the information on Client Reports and promptly notify of us of any errors or discrepancies. Item 16 – Investment Discretion The Firm offers discretionary management services. At this time, the firm does not offer non- discretionary management. In a non-discretionary account arrangement, the client must approve each of our recommendations and make the ultimate decision regarding the purchase or sale of investments. Clients sign an agreement granting the Firm discretionary authority to select the securities and the quantities or amounts of securities to be purchased, leveraged, transferred, exchanged, traded, and sold, consistent with the client’s stated investment objectives, risk profile, and investment restrictions. The Firm's discretionary authority is limited by (1) any reasonable restrictions that the client places on the management of the account, and (2) the investing parameters set forth by the Firm and the client, if any. If the Firm deems a proposed restriction unreasonable, the Firm may discontinue the advisory service. Reasonability is based on whether the restriction(s) will impose a significant time burden on the Firm to comply with such restrictions. The Firm does not obtain authority to designate the broker/dealers or other financial intermediaries through whom transactions in the accounts will be executed, cleared or settled. Item 17 – Voting Client Securities As a matter of policy and practice, the Firm does not have the authority to vote proxies on behalf of advisory clients and does not do so. Clients retain the responsibility for receiving and voting proxies for any and all securities owned by the client. The client’s custodian will mail all correspondence related to proxies, class action lawsuits, legal proceedings, bankruptcies, and proceedings involving an issuer whose securities are held in the client’s account directly to each client. Any required action is the responsibility of the client. Generally, the Firm does not provide clients with advice on voting proxies. We may provide general information and answer general client questions regarding proxy voting to the extent the firm has relevant knowledge or information. Please contact us at the telephone number listed on the cover page of this Brochure to obtain a copy of our Proxy Voting Policy Item 18 – Financial Information We are required in this Item to provide you with certain information or disclosures regarding our financial condition. Following is the information responsive to this Item:  The Firm does not require prepayment of more than USD $500 in fees more than 6 months in advance.  There are no financial conditions or commitments that are likely to impair The Firm’s ability to meet any contractual or fiduciary commitment to our clients.  The Firm has not been the subject of a bankruptcy petition. 19