CARDINAL POINT WEALTH MANAGEMENT

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure March 2026 3280 Bloor Street West, Centre Tower, Suite 500 Toronto, ON Canada M8X 2X3 Toll Free: (866) 213-2036 Office: (647) 598-3951 www.CardinalPoint-Capital.com Firm Contact: Matthew Zienty Chief Compliance Officer This brochure provides information about the qualifications and business practices of Cardinal Point Capital Management, ULC, dba Cardinal Point Wealth Management. If you have any questions about the contents of this brochure, please contact us toll free at (866) 213-2036 or (602)374-3727. 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. Additional information about Cardinal Point Capital Management, ULC is also available on the SEC’s website at www.adviserinfo.sec.gov. Registration as an investment adviser, or any reference to the firm being “registered”, does not imply a certain level of skill or training. 1  Item 2: Material Changes This item of the Brochure summarizes material changes that have been made to the Brochure since our annual updating amendment in March 2026. Since that annual updating amendment, our firm has the following material change(s) to disclose. We help our clients obtain certain tax solutions by introducing clients to the tax professionals of our affiliate, Focus Partners Wealth, LLC (“Focus Tax”). Further information is available in Item 10 of this Brochure. Our firm now requires a minimum account balance of $2,000,000 to open and maintain an account for our Portfolio Management services. This account balance minimum may be waived at any time at our firm’s discretion. Our firm further requires a minimum fee of $23,000 when assets under management fall below $2,000,000. 2  Item 3: Table of Contents Item 1: Cover Page................................................................................................................................. 1 Item 2: Material Changes ..................................................................................................................... 2 Item 3: Table of Contents ..................................................................................................................... 3 Item 4: Advisory Business ................................................................................................................... 4 Item 5: Fees & Compensation ............................................................................................................. 7 Item 6: Performance-Based Fees & Side-By-Side Management ................................................. 10 Item 7: Types of Clients & Account Requirements ....................................................................... 11 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .......................................... 11 Item 9: Disciplinary Information ..................................................................................................... 21 Item 10: Other Financial Industry Activities & Affiliations ........................................................ 21 Item 11: Code of Ethics, Participation or Interest in .................................................................... 25 Item 12: Brokerage Practices ........................................................................................................... 26 Item 13: Review of Accounts or Financial Plans ........................................................................... 28 Item 14: Client Referrals & Other Compensation ......................................................................... 28 Item 15: Custody .................................................................................................................................. 30 Item 16: Investment Discretion ........................................................................................................ 31 Item 17: Voting Client Securities ...................................................................................................... 32 Item 18: Financial Information ........................................................................................................ 32 3  Item 4: Advisory Business Cardinal Point Wealth Management (“Cardinal Point”) was formed in November 2002. Cardinal Point was first registered as an investment adviser with the United States Securities and Exchange Commission in May 2006. Cardinal Point is also registered as a Portfolio Manager with each of the following Canadian Securities Commissions: British Columbia Securities Commission, Alberta Securities Commission, Manitoba Securities Commission, Nova Scotia Securities Commission, Ontario Securities Commission, New Brunswick Securities Commission, Saskatchewan Financial Services Commission, the Quebec Financial Markets Authority, the Prince Edward Island Financial and Consumer Services Division, and the Newfoundland and Labrador, Financial Services Regulation Division. Focus Financial Partners Cardinal Point is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Cardinal Point is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Cardinal Point is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Cardinal Point. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private 3: Table of Contents funds, or investment companies as disclosed on their respective Form ADVs. The Firm’s Services As discussed below in this Disclosure Brochure, Cardinal Point offers comprehensive portfolio management services, non-discretionary investment advice and financial planning services. Portfolio Management Services: Our Portfolio Management service encompasses asset management as well as providing general financial planning to our clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her 4  financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Financial planning services are included in our Portfolio Management service. Generally, our Canada, U.S. and cross-border financial planning services will involve preparing a financial plan for clients Financial Planning: based on the client’s financial goals and objectives. CPCM shall provide ongoing financial planning services to the client. Financial planning services shall involve rendering financial advice in the form of financial planning memos and/or a full financial plan based on the client’s financial goals and objectives. CPCM shall provide the Client with a written summary of their financial situation, as well as CPCM’s observations and recommendations for a course of activity or specific actions to be taken by the Client. CPCM may refer the Client to an accountant, attorney, or other specialist as necessary for non-advisory related services. Tax Preparation: Our tax preparation services include preparing U.S and Canada personal, corporate and trust returns. Private Wealth (Bundled) Services: Private Wealth (Bundled) Services provide clients with bundled comprehensive portfolio management, financial planning, and tax preparation services. These services provide assistance in planning for and executing financial strategies, which may be customized to fit each client’s individual needs to meet his or her goals. This service is no longer offered to new clients. Some legacy clients may still participate in this program. UPTIQ Treasury & Credit Solutions, LLC We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. Affiliate Private Investment Vehicles We have business arrangements with a subsidiary or subsidiaries of Origin Investments Group, LLC (“Origin”), Westcourt Capital Corporation (“Westcourt”), as well as SCS Capital Management LLC (“SCS”), who are each an indirect, wholly-owned subsidiary of Focus LLC, under which certain clients of Cardinal Point have the option of investing in certain private investment vehicles managed by Origin, Westcourt, or SCS. Cardinal Point is an affiliate of Origin, Westcourt, and SCS by virtue of being under common control with all entities. Please see Items 5, 10, and 11 of this Brochure for further details. Focus Risk Solutions, LLC We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial 5  Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. Held-Away Accounts We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). For certain clients, we charge an advisory fee for services provided to the held-away accounts mentioned above, just as we do with client accounts held at our primary custodian(s). The specific fee schedule charged by us is provided in the client’s investment advisory agreement with us. Pontera The order management system that we use for held-away accounts is provided by Pontera Solutions, Inc. We review, monitor, and manage these held-away accounts in an integrated way with client accounts held at our clients’ primary custodian(s). Further information about this service is available in Item 5. Tailoring of Advisory Services We offer individualized investment advice to clients utilizing our firm’s advisory services. Additionally, we offer general investment advice to Financial Planning clients. We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing their account. In the rare instance that we would allow restrictions, it would be limited to our firm’s asset management services. We do not manage assets through our other services. Miscellaneous Information About the Firm’s Services In connection with the provision of Cardinal Point’s services, (1) Cardinal Point tailors its advisory services to the client’s individual needs, (2) clients may (but typically do not) impose reasonable restrictions on Cardinal Point’s services, which may include restrictions on investing in certain securities or types of securities, (3) Cardinal Point is authorized to rely on any and all information that is provided to Cardinal Point by the client or any of the client’s other professionals (such as the client’s attorney or accountant), and shall not be required to independently verify any such information, and (4) each client is responsible to promptly notify Cardinal Point if there is ever any change in their financial situation or investment objectives so that Cardinal Point is positioned to review, evaluate and possibly revise its previous recommendations and/or services. Fiduciary Status As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any non-waivable rights you possess. 6  Retirement Accounts Cardinal Point is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. Cardinal Point is also a fiduciary under Section 4975 of the Internal Revenue Code of 1986, as amended (“the IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, Cardinal Point is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on Participation in Wrap Fee Programs conflicts of interest. Regulatory Assets Under Management Our firm does not offer or sponsor a wrap fee program. Our firm manages $4,787,749,652.94 on a discretionary basis and $20,547,014.04 on a non- discretionary basis. For a total of asset under management of $4,808,296,666.98 as of December 31, 2025. Item 5: Fees & Compensation Compensation for Our Advisory Services Cardinal Point Capital Management ULC. Portfolio Management and Financial Planning Fee Schedule Assets Under Management Fee Rate (per annum) 1.25% First $1,000,000 Next $2,000,000 1.05% Next $4,000,000 0.80% 0.55% Next $3,000,000 Next $5,000,000 0.45% Next $10,000,000 0.35% 0.25% Next Assets Above $25,000,000 Please note: CPCM charges blended rate fees when applicable. A blended rate fee schedule combines annual percentages into a cumulative fee based on a client’s asset level. Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Our firm bills on cash, accrued interest, accrued dividends, and securities purchased on margin unless indicated otherwise in writing. Please note, CPCM charges blended rate fees when applicable. A 7  blended rate fee schedule combines annual percentages into a cumulative fee based on a client’s asset level. Annualized fees are billed on a pro-rata basis quarterly in arrears based on the value of the account(s) on the time-weighted daily average of the quarter. Fees are generally non-negotiable, however, the firm in its sole discretion may reduce its account minimum or the fee that it charges to clients. Fees will generally be deducted from client account(s). In rare cases, our firm will agree to directly invoice. As part of this process, Clients understand the following: a) b) c) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. It is important to note that clients who receive a comprehensive written Financial Plan as part of these services will be required to pay our minimum fee of $23,000 if assets under management are below $2,000,000. Pontera® ® ® ® Clients should note that our firm will utilize the Pontera platform to aid in the management of accounts held away from our primary custodian. It is important to note in exchange for the use of platform our firm must pay a fee of 0.25% of the managed assets. All fees due to the Pontera Pontera are paid by our firm and will not result in the client paying higher fees than if their assets Financial Planning: were managed through our recommended Custodians. Our firm charges on an hourly or flat fee basis for financial planning services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. The maximum hourly fee to be charged will not exceed $400. Flat fees begin at $23,000. Our firm requires a retainer of 50% of the ultimate financial planning fee at the time of signing. The remainder of the fee will be directly billed to the client and due within 30 days of a financial plan being delivered. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months. Private Wealth (Bundled) Services This service is no longer offered to new clients. Some acquisition legacy clients may still participate in this bundled program and the fee will be outlined in their respective executed advisory agreements. Affiliate Private Investment Vehicles We do not receive any compensation from Origin, Westcourt, or SCS in connection with assets that our clients place in Origin’s, Westcourt’s, or SCS’s pooled investment vehicles. Cardinal Point’s clients are not advisory clients of and do not pay advisory fees to Origin, Westcourt, or SCS. However, our 8  clients bear the costs of Origin’s, Westcourt’s, and SCS’s investment vehicle or vehicles in which they are invested, including any management fees and performance fees payable to Origin, Westcourt, or SCS. The allocation of Cardinal Point client assets to Origin’s, Westcourt’s, and SCS’s pooled investment vehicles, rather than to an unaffiliated investment manager, increases Origin’s, Westcourt’s, and SCS’s compensation and the revenue to Focus LLC relative to a situation in which our clients are excluded from Origin’s, Westcourt’s, or SCS’s pooled investment vehicles or invested in an unaffiliated third party's pooled investment vehicles. As a consequence, Focus LLC has a financial incentive to cause Other Types of Fees & Expenses us to recommend that our clients invest in Origin’s, Westcourt’s, or SCS’s pooled investment vehicles. Clients will incur transaction charges for trades executed in their accounts. These transaction fees are separate from our fees and will be disclosed by the firm that the trades are executed through. In addition, clients may incur additional fees and expenses, including custodial fees, transfer taxes, withholding fees, country tax or delivery fees, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. For more information regarding our brokerage practices, see Item 12 below. Clients will pay the following separately incurred expenses, which we do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). This may result in the layering of fees, as such fees are borne by investors in those vehicles, including our clients, in addition to management fees paid directly to us. Clients who subscribe to our Portfolio Management services may also pay additional fees to unaffiliated third- party investment advisers who provide advisory services to some or all of the assets that are under our advisement. Termination & Refunds Portfolio Management: We charge our advisory fees quarterly in arrears. If you wish to terminate our services, you need to contact us in writing and state that you wish to cancel the advisory agreement. Upon receipt of your letter of termination, we will proceed to delink our firm from your account and charge you a pro-rata advisory fee(s) for services rendered up to the point of termination. Financial Planning/Tax Preparation: Clients may terminate their agreement at any time before the delivery of a financial plan or the completion of the tax preparation service by providing written notice. For purposes of calculating refunds, all work performed by us up to the point of termination shall be calculated at the hourly fee currently in effect. If applicable, Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our firm. Commissionable Securities Sales We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Focus Financial Partners, LLC (“Focus”) is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ Inc.’s investors, 9  including Focus, our parent company. When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial institutions. For other loans (except residential mortgage loans) made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from such third-party financial institutions. For cash management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries that provide administrative and settlement services in connection with this program. Although the amount of these revenue-sharing payments to FSH is not charged directly in the calculation of the interest rate paid by clients on credit solutions facilitated by UPTIQ or the yield earned by clients on cash management solutions facilitated by UPTIQ, the compensation earned by UPTIQ is an expense of the third-party financial institutions that informs the interest rate paid by clients on credit solutions and the yield earned by clients on cash management solutions. FSH distributes this revenue to us when we are licensed to receive such revenue (or when no such license is required) and the distribution is not otherwise legally prohibited. Further information on this conflict of interest is available in Item 10 of this Brochure. We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters and placing products for them and/or referring our clients to certain third- party insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place insurance products for them. If FRS refers one of our clients to a Broker and there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the upfront and/or ongoing commissions paid to the Broker by the insurance carrier with which the policy was placed. The amount of revenue earned by FRS for the sale of these insurance products will vary over time in response to market conditions and will also differ based on the type of insurance product sold and which Broker placed the policy. The amount of insurance commission revenue earned by FRS is considered for purposes of determining the amount of additional compensation that certain of our financial professionals are entitled to receive. Additionally, in exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’’ clients, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in such revenue. FRS also independently benefits from our clients’ use of the services insofar as such use incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to FRS, which could also support increases in the overall amount of the Platform Fee rates in the future. Further information on this conflict of interest is available in Item 10 of this Brochure. Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees. 10  Item 7: Types of Clients & Account Requirements Our firm has the following types of clients: • • • Individuals and High Net Worth Individuals; Trusts, Estates or Charitable Organizations; Corporations, Limited Liability Companies and/or Other Business Types Our requirements for opening and maintaining accounts or otherwise engaging us: Our firm requires a minimum account balance of $2,000,000 for our Portfolio Management services. Generally, this minimum account balance requirement is not negotiable and would be required throughout the course of the client’s relationship with our firm. For clients who have assets under $2,000,000 and are to receive a written Financial Plan, a minimum fee of $23,000 will apply. It is important to note that these minimum service fees and account requirements may be waived at the firm’s discretion. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Our investment advice is based on a long-term investment approach that incorporates globally diversified, asset allocation strategies. When formulating our investment advice and/or managing client assets, we ensure the investment strategies are appropriate to the needs of the client and consistent with the client's investment objectives and goals, risk tolerance, and time horizons, among other considerations. Methods of Analysis Security analysis methods may include analyzing the economic characteristics of sectors and asset classes as well as some fundamental and technical analysis. The main sources of information include financial publications, research materials provided by other investment institutions, corporate rating services, annual reports, prospectuses, and company press releases. Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the security is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis: We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. 11  Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. The underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as our firm does not control the underlying investments in a fund or ETF, managers of different funds held by the Client may purchase the same security, increasing the risk to the Client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the Client’s portfolio. Investment Strategies & Asset Classes There are several types of asset allocation strategies based on investment goals, risk tolerance, time frames and diversification. The asset allocation in a client’s Investment Policy Statement includes a mix of income-oriented assets (Bonds) and growth-oriented assets (Stocks) that considers risk tolerance and investment objectives and is combined with a smaller weighting toward Alternatives, meant to balance out different risks to a portfolio and enhance diversification. Then we apply academic research to determine the best mix of asset classes for the income and growth assets. In practice, we utilize a Core and Satellite approach. This approach assigns the largest weights to those Core areas of the market- such as U.S. Stocks, Canadian Stocks, International Stocks and Investment Grade bonds. By using index-based investments in many instances, we avoid the risk of dramatic underperformance associated with active management in these Core components. Research over the past twenty years has found that in well-diversified portfolios, the asset mix accounts for over ninety percent of the variation of returns over time. • Our Core positions target their relative asset class returns, focusing on: • broad diversification • minimal cost • low turnover • tax efficiency • liquidity transparency This allows investors to participate in market returns regardless of where or what type of companies those returns are coming from. 12  We then add on smaller Satellite positions with the goals of either higher expected returns or enhanced diversification. Securities employed within the Satellite adhere to our rigorous quantitative and qualitative security screening process. Examples of these positions would be securities targeting factor premiums in the equity space, including Value, Small, Momentum, or High Profitability stocks. Other areas such as Low Volatility Stocks, International Bonds, and Emerging Market Stocks may be added to improve diversification. Finally, other allocations to Alternative Assets such as Real Estate Investment Trusts, Market Neutral Strategies, Commodities or Private Market exposures (Private Equity, Private Credit, Private Infrastructure) round out the smaller allocations considered Satellite positions. All of these positions are meant to broaden overall diversification and deliver lower correlation to the core positions. The Satellite component is managed using a tactical investment strategy, and holdings within the portfolios can be increased or decreased as deemed prudent, for example as the size of an account grows, there may be additional investment options available within the Satellite component to consider. Satellite holdings are typically held for at least one year, if not longer. Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus reward by adjusting the percentage of each asset in an investment portfolio according to the investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle that different assets perform differently in different market and economic conditions. A fundamental justification for asset allocation is the notion that different asset classes offer returns that are not perfectly correlated, hence diversification reduces the overall risk in terms of the variability of returns for a given level of expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation and variance) that existed over some past period. Expectations for return are often derived in the same way. investment-grade or An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return. There are many types of assets that may or may not be included in an asset allocation strategy. The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign [developed], emerging or frontier markets), bonds (fixed income securities more junk [high-yield]; government or corporate; short-term, generally: intermediate, long- term; domestic, foreign, emerging markets), and cash or cash equivalents. Alternaive asset classes would include areas such as commodities, real estate, hedge fund strategies, private markets exposures such as private equity, private credit and private infrastructure. Allocation among these three provides a starting point. Long-Term Purchases: When utilizing this strategy, we purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short- term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. 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 strategy will be profitable or suitable for a client’s portfolio. Past performance is not indicative of future results. Cardinal Point seeks to tailor its recommendations and investment strategies to each client’s objectives, financial circumstances, risk tolerance, and liquidity needs; 13  however, all investing involves risk, including the possible loss of principal. Cardinal Point may recommend or invest client assets in a variety of securities and investment vehicles, including, but not limited to, exchange-traded funds, mutual funds, individual equity securities, fixed income securities, cash equivalents, interval funds, alternative funds, and private funds. The material risks associated with these investments include, without limitation, the following: Exchange-Traded Funds (“ETFs”) Cardinal Point may recommend exchange-traded funds (“ETFs”). ETFs are pooled investment vehicles that typically seek to track the performance of an index, sector, commodity, or basket of securities, although some ETFs are actively managed. ETF shares trade on securities exchanges during the trading day at market prices, which may be above or below the fund’s net asset value (“NAV”). Investing in ETFs involves risk, including the risk of loss of principal. ETF investors are subject to the risks of the underlying securities held by the fund, as well as the risk that the ETF may not track its benchmark as intended. Tracking error may result from management fees, operating expenses, trading costs, portfolio construction, cash holdings, and other factors. In addition to the advisory fees paid to Cardinal Point, clients who invest in ETFs bear their proportionate share of the ETF’s internal management fees and operating expenses and will generally incur brokerage or transaction costs in connection with purchases and sales. Although ETFs are designed to be liquid, there can be no assurance that an active trading market will exist or be maintained, or that shares will trade at prices close to NAV. Mutual Funds Cardinal Point may recommend mutual funds. Mutual funds pool assets from many investors and invest according to stated objectives and strategies. Mutual fund shares are typically purchased and redeemed at NAV, which is generally calculated once each business day after the close of trading. Mutual funds involve risk, including the risk of loss of principal. Mutual funds are subject to the risks of the securities they hold and the strategies they employ. In addition to the advisory fees paid to Cardinal Point, clients investing in mutual funds indirectly bear their proportionate share of the fund’s management fees, operating expenses, and, where applicable, sales charges, distribution fees, or redemption fees. Mutual funds may also distribute taxable dividends and capital gains, which may create tax consequences even if shares are not sold. Because mutual funds are priced only once per day, clients do not receive intraday pricing and do not control the underlying portfolio management decisions. Individual Stocks Cardinal Point may recommend investments in individual equity securities, including common and preferred stocks. Equity securities represent an ownership interest in an issuer and may be used to pursue capital appreciation, income, or a combination of both. Investing in individual stocks involves risk, including the risk of loss of principal. The value of an 14  individual stock may fluctuate significantly in response to company-specific developments, market conditions, economic events, interest rate changes, investor sentiment, or other factors. Stockholders are subordinate to creditors and bondholders in an issuer’s capital structure and may lose some or all of their investment if the issuer performs poorly or becomes insolvent. Individual stocks may also be more volatile and less diversified than pooled investment vehicles, particularly where a portfolio holds a limited number of issuers or has meaningful exposure to a particular company, industry, or sector. Certain stocks may pay dividends, but there can be no assurance that dividends will be maintained. Fixed Income Securities Cardinal Point may recommend fixed income securities, including, but not limited to, U.S. Treasury securities, agency securities, corporate bonds, municipal bonds, certificates of deposit, commercial paper, money market instruments, asset-backed securities, and other debt obligations. Fixed income securities may be used for income generation, liquidity management, capital preservation objectives, and portfolio diversification. Fixed income securities involve a variety of risks, including interest rate risk, credit risk, default risk, downgrade risk, call risk, reinvestment risk, inflation risk, liquidity risk, and market risk. Generally, bond prices decline when interest rates rise, and longer-duration securities are typically more sensitive to changes in interest rates. Lower-rated and unrated debt securities generally involve greater credit and default risk than higher-rated obligations. Certain debt securities may be callable or subject to early redemption, which may require reinvestment at less favorable rates. In periods of market stress or reduced liquidity, certain fixed income securities may be difficult to value or sell. International and non-U.S. dollar denominated fixed income securities may involve additional risks, including currency risk, sovereign risk, and political or economic risk. Credit ratings assigned by rating agencies reflect their opinions regarding an issuer’s creditworthiness, but they do not eliminate market risk or guarantee future performance. Cardinal Point seeks to manage fixed income risks through diversification, credit review, duration management, and ongoing monitoring; however, there can be no assurance that these efforts will be successful. Cash Positions and Money Market Funds At many custodians used by Cardinal Point, cash balances are swept automatically into money market funds, insured deposit programs, or other cash sweep vehicles as part of the custodian’s standard account arrangement. In addition, Cardinal Point may recommend that clients maintain cash or cash equivalents for liquidity, rebalancing, distributions, fees, or other portfolio management purposes. Cash and cash equivalent positions are generally intended to emphasize liquidity and capital preservation, but they are not risk-free. Depending on the vehicle used, such positions may be subject to interest rate risk, inflation risk, credit risk, issuer risk, liquidity risk, and, where applicable, fund expenses. Money market funds are not bank deposits and are not guaranteed by the Federal Deposit Insurance Corporation or any other government agency unless specifically stated. Holding cash or cash equivalents may also reduce a client’s overall return, particularly during periods in which risk assets appreciate. 15  Interval Funds Cardinal Point may recommend interval funds where appropriate. Interval funds are generally registered closed-end management investment companies that do not provide daily liquidity. Unlike traditional mutual funds, interval funds typically repurchase shares only periodically through limited repurchase offers, often quarterly and subject to advance notice and fund-specific procedures. Investments in interval funds involve substantial liquidity risk. Shares generally are not listed on an exchange, are not publicly traded, and typically have no secondary market. As a result, clients may be unable to liquidate their investment promptly or in the desired amount. Even during a repurchase offer period, an interval fund may limit the number of shares it repurchases, and repurchase requests may be reduced on a pro rata basis if oversubscribed. An interval fund may also suspend, postpone, or otherwise limit repurchases in certain circumstances. In addition, some interval funds may have limited subscription capacity and may not accept all purchase requests. Interval funds may invest in less liquid or more complex assets, and some may use leverage. The use of leverage can increase volatility and magnify losses. If an interval fund borrows to meet repurchase requests or for investment purposes, the fund’s expenses may increase and returns may be adversely affected. Because of these risks, interval funds generally are appropriate only for clients with a longer-term investment horizon, sufficient risk tolerance, and no near-term need for liquidity. Clients should review the applicable prospectus and shareholder reports carefully to understand the fund’s structure, investment strategy, fees, repurchase procedures, and risks before investing. Alternative Funds Cardinal Point may recommend certain alternative funds registered under the Investment Company Act of 1940. These funds may pursue strategies that differ significantly from traditional stock and bond funds and may use derivatives, futures, options, swaps, short sales, structured products, or leverage as part of their investment programs. Alternative funds involve special risks that may be greater than those associated with traditional investments. These risks may include leverage risk, counterparty risk, liquidity risk, valuation risk, derivatives risk, short sale risk, correlation risk, and strategy risk. The use of leverage or certain derivative instruments can magnify gains and losses, increase volatility, and, in some cases, result in losses greater than would be expected in unleveraged strategies. Alternative strategies may also underperform during certain market environments and may not provide the intended diversification or hedging benefits. In addition to the advisory fees paid to Cardinal Point, clients investing in alternative funds indirectly bear their proportionate share of the fund’s management fees, operating expenses, and other costs. Clients should carefully review the applicable prospectus or offering documents to understand the fund’s strategy, risks, liquidity terms, and fee structure. These investments generally are appropriate only when consistent with a client’s investment objectives, financial circumstances, risk tolerance, and liquidity needs. 16  Private Funds and Private Equity/Venture Capital Vehicles Cardinal Point may recommend private funds or other privately offered investment vehicles where appropriate. These investments may include drawdown or capital commitment structures, including funds that invest in private equity, venture capital, private credit, real assets, or other alternative strategies. In certain cases, Cardinal Point may recommend a drawdown vehicle sponsored by SCS or a similar manager that calls capital over time and has an expected long-term investment horizon, which may extend to approximately twelve years or longer. Private funds involve substantial risks and are generally suitable only for clients who can bear the economic risk of the investment, including the loss of some or all of the invested capital, and who do not require liquidity. Such investments are typically illiquid, are not publicly traded, and may be subject to transfer restrictions, limited redemption rights, or no redemption rights at all. Capital may be called over an extended period of time, and clients are generally required to meet capital calls when due. Failure to do so may result in penalties, dilution, forfeiture, or other adverse consequences under the governing documents. Private funds also involve risks relating to valuation, leverage, concentration, manager discretion, lack of transparency, and limited operating history in certain strategies or portfolio companies. Valuations may be based on estimates, appraisals, or other methods that are inherently subjective, and reported values may not reflect realizable market prices. Private equity and venture capital strategies are particularly speculative and may involve portfolio companies with limited operating histories, evolving business models, dependence on external financing, and heightened business, market, and execution risk. These investments may take many years to realize, if at all, and returns may be highly uncertain. In addition to the advisory fees paid to Cardinal Point, clients investing in private funds generally bear their proportionate share of the fund’s management fees, performance-based compensation or carried interest, organizational and administrative expenses, and underlying portfolio expenses. These layered fees and expenses can materially reduce returns. Clients should carefully review the applicable private placement memorandum, limited partnership agreement, subscription documents, capital call procedures, and other offering materials to understand the investment strategy, risks, fees, liquidity limitations, and term of the investment. Private funds generally are appropriate only when consistent with a client’s investment objectives, financial circumstances, risk tolerance, qualification status, and liquidity needs. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease, and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask us any questions you may have. Additional risks associated with the Methods of Analysis, Investment Strategies and Asset Classes listed above include: Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may lose 100% of your money. All investments carry some form of risk and the loss of capital is generally a risk for any investment instrument. 17  Company Risk: When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or unfavorable performance if a borrower does not repay the borrowed funds as expected or required. Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit risk. Currency Risk: Fluctuations in the value of the currency in which your investment is denominated may affect the value of your investment and thus, your investment may be worth more or less in the future. All currency is subject to swings in valuation and thus, regardless of the currency denomination of any particular investment you own, currency risk is a realistic risk measure. That said, currency risk is generally a much larger factor for investment instruments denominated in currencies other than the most widely used currencies (U.S. dollar, British pound, German mark, Euro, Japanese Yen, French Franc, etc.). Cybersecurity and Operational Risk: The computer systems, networks and devices used by Cardinal Point and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. Economic Risk: The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that 18  experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. ETF & Mutual Fund Risk : When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also incur brokerage costs when purchasing ETFs. Financial Risk: Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk, which is the risk that their value will generally decline as prevailing interest rates rise, which may cause your account value to likewise decrease, and vice versa. How specific fixed income securities may react to changes in interest rates will depend on the specific characteristics of each security. Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of a bond to decline. Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds from your investment will not be worth what they are today. Throughout time, the prices of resources and end-user products generally increase and thus, the same general goods and products today will likely be more expensive in the future. The longer an investment is held, the greater the chance that the proceeds from that investment will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get you less than what it can today. Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing interest rates in the market will have an inverse relationship to the value of existing, interest paying investments. In other words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well. Legal/Regulatory Risk: Certain investments or the issuers of investments may be affected by 19  changes in state or federal laws or in the prevailing regulatory framework under which the investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws can affect the performance of certain investments or issuers of those investments and thus, can have a negative impact on the overall performance of such investments. Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited market in which they trade. Thus, you may experience the risk that your investment or assets within your investment may not be able to be liquidated quickly, thus, extending the period of time by which you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment before the price drops significantly) a particular investment and therefore, can have a negative impact on investment returns. Long-Term Purchase Risk: Our firm may buy securities for your account and hold them for a relatively long time (more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that could have been profitable to your account, or it’s possible that the security’s value may decline sharply before our firm make a decision to sell. Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns Certain illnesses spread rapidly and have the potential to significantly and adversely affect the global economy. Epidemics and/or pandemics have and may further result in, among other things, closing borders, enhanced health screenings, healthcare service preparation and delivery, quarantines, cancellations, disruptions to supply chains and customer activity, as well as general concern and uncertainty. The impact of such epidemics and/or pandemics that may arise in the future have the potential to affect the economies of many nations, individual companies and the global securities and commodities markets, including liquidity, in ways that cannot necessarily be foreseen at the present time. The impact of infectious diseases in developing or emerging market countries may be greater due to less established health care systems. Health crises caused by the recent coronavirus outbreak may exacerbate other preexisting political, social and economic risks in certain countries. The impact of the outbreak may last for an extended period of time and may have material adverse impacts. Market Timing Risk: Market timing can include high risk of loss since it looks at an aggregate market versus a specific security. Timing risk explains the potential for missing out on beneficial movements in price due to an error in timing. This could cause harm to the value of an investor's portfolio because of purchasing too high or selling too low. 20  Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Neither our firm nor any of its management persons is registered or have an application pending to be registered with a broker-dealer. Neither our firm nor any of its management persons is a commodity broker/futures commission merchant, a commodity pool operator, commodity trading advisor or an associated person for the foregoing entities or has an application for registration pending. Focus Financial Partners As noted above in response to Item 4, certain investment vehicles affiliated with CD&R collectively are indirect majority owners of Focus LLC., and certain investment vehicles affiliated with Stone Point are indirect owners of Focus LLC. Because Cardinal Point is an indirect, wholly-owned subsidiary of Focus LLC., CD&R and Stone Point investment vehicles are indirect owners of Cardinal Point. UPTIQ Credit and Cash Management Solutions We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). These third-party financial institutions are banks and non-banks that offer credit and cash management solutions to our clients, as well as certain other unaffiliated third parties that provide administrative and settlement services to facilitate UPTIQ’s cash management solutions. UPTIQ acts as an intermediary to facilitate our clients’ access to these credit and cash management solutions. We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ Inc.’s investors, including Focus. When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial institutions. For other loans (except residential mortgage loans) made to our clients, UPTOQ will share with FSH up to 25% of all revenue it receives from such third- party financial institutions. For cash management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries that provide administrative and settlement services in connection with this program. Although the amount of these revenue-sharing payments to FSH is not charged directly in the calculation of the interest rate paid by clients on credit solutions 21  facilitated by UPTIQ or the yield earned by clients on cash management solutions facilitated by UPTIQ, the compensation earned by UPTIQ is an expense of the third-party financial institutions that informs the interest rate paid by clients on credit solutions and the yield earned by clients on cash management solutions. FSH distributes this revenue to us when we are licensed to receive such revenue (or when no such license is required) and the distribution is not otherwise legally prohibited. This revenue is also revenue for FSH’s and our common parent company, Focus. Additionally, the volume generated by our clients’ transactions allows Focus to negotiate better terms with UPTIQ, which benefits Focus and us. Accordingly, we have a conflict of interest when recommending UPTIQ’s services to clients because of the compensation to us and to our affiliates, FSH and Focus, and the transaction volume to UPTIQ. We mitigate this conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our clients, including in this Brochure; and (2) offering UPTIQ’s solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services. Additionally, we note that clients who use UPTIQ’s services will receive product-specific disclosure from the third-party financial institutions and other unaffiliated third-party intermediaries that provide services to our clients. We have an additional conflict of interest when we recommend credit solutions to our clients because our interest in continuing to receive investment advisory fees from client accounts gives us a financial incentive to recommend that clients borrow money rather than liquidate some or all of the assets we manage. Credit Solutions Clients retain the right to pledge assets in accounts generally, subject to any restrictions imposed by clients’ custodians. While credit solution programs that we offer facilitate secured loans through third-party financial institutions, clients are free instead to work directly with institutions outside such programs. Because of the limited number of participating third-party financial institutions, clients may be limited in their ability to obtain as favorable loan terms as if the client were to work directly with other banks to negotiate loan terms or obtain other financial arrangements. Clients should also understand that pledging assets in an account to secure a loan involves additional risk and restrictions. A third-party financial institution has the authority to liquidate all or part of the pledged securities at any time, without prior notice to clients and without their consent, to maintain required collateral levels. The third-party financial institution also has the right to call client loans and require repayment within a short period of time; if the client cannot repay the loan within the specified time period, the third-party financial institution will have the right to force the sale of pledged assets to repay those loans. Selling assets to maintain collateral levels or calling loans may result in asset sales and realized losses in a declining market, leading to the permanent loss of capital. These sales also may have adverse tax consequences. Interest payments and any other loan- related fees are borne by clients and are in addition to the advisory fees that clients pay us for managing assets, including assets that are pledged as collateral. The returns on pledged assets may be less than the account fees and interest paid by the account. Clients should consider carefully and skeptically any recommendation to pursue a more aggressive investment strategy in order to support the cost of borrowing, particularly the risks and costs of any such strategy. More generally, before borrowing funds, a client should carefully review the loan agreement, loan application, and other forms and determine that the loan is consistent with the client’s long-term financial goals and presents risks consistent with the client’s financial circumstances and risk tolerance. We use UPTIQ to facilitate credit solutions for our clients. 22  Cash Management Solutions For cash management programs, certain third-party intermediaries provide administrative and settlement services to our clients. Engaging the third-party financial institutions and other intermediaries to provide cash management solutions does not alter the manner in which we treat cash for billing purposes. Clients should understand that in rare circumstances, depending on interest rates and other economic and market factors, the yields on cash management solutions could be lower than the aggregate fees and expenses charged by the third-party financial institutions, the intermediaries referenced above, and us. Consequently, in these rare circumstances, a client could experience a negative overall investment return with respect to those cash investments. Nonetheless, it might still be reasonable for a client to participate in a cash management program if the client prefers to hold cash at the third-party financial institutions rather than at other financial institutions (e.g., to take advantage of FDIC insurance). We use UPTIQ to facilitate cash management solutions for our clients. Focus Risk Solutions We help our clients obtain certain insurance products by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC (“Focus”). FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters and placing insurance products for them and/or referring our clients to certain third-party insurance brokers (the “Brokers”) , with whom FRS has agreements, which either separately or together with FRS place insurance products for them. If FRS places an insurance product or refers one of our clients to a Broker and there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy was placed. The amount of revenue earned by FRS for the sale of these insurance products will vary over time in response to market conditions and will also differ based on the type of insurance product sold and which Broker placed the policy. The amount of insurance commission revenue earned by FRS is considered for purposes of determining the amount of additional compensation that certain of our financial professionals are entitled to receive. This revenue is also revenue for our and FRS’s common parent company, Focus. Additionally, in exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’ clients, FRS receives periodic fees (“Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share such revenue. FRS also indirectly benefits from our clients’ use of the services insofar as such use incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to FRS, which could also support increases in the overall amount of the Platform Fee rates in the future. Accordingly, we have a conflict of interest when recommending FRS’s services to clients because of the compensation to certain of our financial professionals and to our affiliates, FRS and Focus. We address this conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our clients, including this Brochure; (2) offering FRS solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services; and (3) not sharing in any portion of the Platform Fees0/. Additionally, we note that clients who use 23  FRS’s services will receive product-specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party intermediaries that provide services to our clients. The insurance premium is ultimately dictated by the insurance carrier, although in some circumstances the Brokers or FRS may have the ability to influence an insurance carrier to lower the premium of the policy. The final rate may be higher or lower than the prevailing market rate, and may be higher than if the policy was purchased directly through the Broker without the assistance of FRS. We can offer no assurances that the rates offered to you by the insurance carrier are the lowest possible rates available in the marketplace. Affiliate Private Investment Vehicles vehicles. More information about Focus LLC can be found Cardinal Point has a business relationship with other Focus firms that is material to our advisory business or to our clients. Under certain circumstances we offer our clients the opportunity to invest in pooled investment vehicles managed by Origin, Westcourt, or SCS. Origin, Westcourt, and SCS provide these services to such clients pursuant to limited liability company agreement or limited partnership agreement documents and in exchange for a fund-level management fee and performance fee paid by our clients and not by us. Origin, Westcourt, and SCS, like Cardinal Point, are indirect wholly owned subsidiaries of Focus LLC and are therefore under common control with Cardinal Point. The allocation of our clients’ assets to Origin’s, Westcourt’s, or SCS’s pooled investment vehicles, rather than to an unaffiliated investment manager, increases Origin’s, Westcourt’s, or SCS’s, and indirectly, Focus LLC’s, compensation and revenue. As a consequence, Focus LLC has a financial incentive to cause Cardinal Point to recommend that our clients invest in Origin’s, Westcourt’s, or SCS’s pooled investment vehicles, which creates a conflict of interest with Cardinal Point clients who invest, or are eligible to invest, in Origin’s, Westcourt’s, or SCS’s pooled at investment www.focusfinancialpartners.com. We believe this conflict is mitigated because of the following factors: (1) this arrangement is based on our reasonable belief that investing a portion of Cardinal Point’s clients’ assets in Origin’s, Westcourt’s, or SCS’s investment vehicles is in the best interests of the clients; (2) Origin, Westcourt, SCS and their investment vehicles have met the due diligence and performance standards that we apply to outside, unaffiliated investment managers; (3) clients will invest in the pooled investment vehicles on a nondiscretionary basis through the completion of subscription documentation; (4) subject to redemption restrictions, we are willing and able to reallocate Cardinal Point client assets to other unaffiliated or affiliated investment vehicles, in part or in whole, if Origin’s, Westcourt’s, or SCS’s services become unsatisfactory in our judgment and at our sole discretion; and (5) we have fully and fairly disclosed the material facts regarding this relationship to you, including in this Brochure, and Cardinal Point clients who invest in Origin’s, Westcourt’s, or SCS’s pooled investment vehicles have given their informed consent to those investments. Focus Tax We help our clients obtain certain tax solutions by introducing clients to the tax professionals of our affiliate, Focus Partners Wealth, LLC (“Focus Tax”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Our clients’ use of Focus Tax’s services, rather than the services of an unaffiliated tax preparation and tax compliance firm, increases Focus Partners Wealth, LLC’s compensation and the revenue to Focus LLC relative to a situation in which our clients do not use Focus Tax’s services. Focus LLC has a financial incentive to encourage us to recommend that our clients use Focus Tax’s services, although clients are not obligated to use these services. Clients who 24  do use Focus Tax’s services will sign a separate agreement with Focus Tax agreeing to the services and fees. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading We recognize that the personal investment transactions of employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. The Code of Ethics sets forth certain key policies, including policies with respect to personal securities transactions and insider trading, and specifies the responsibility of all employees to act in accordance with their fiduciary duty to clients. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. A copy of our Code of Ethics will be provided promptly upon request. Our employees are permitted to invest for their own accounts in the same securities, or related securities, that we invest in on behalf of or recommend to clients. In order to minimize this conflict of interest, our employees will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics. In addition, our employees are prohibited from buying or selling a security within 24 hours of buying or selling the same security for our clients unless included in a block trade with clients. If employee accounts are not included in a block trade, personal accounts will always trade last. It is also important to note that Cardinal Point recommends that certain of our clients invest in private investment funds managed by affiliated Focus partner firms. Please refer to Items 4, 5 and 10 for additional information. 25  Item 12: Brokerage Practices Selecting a Brokerage Firm Item 15 While our firm does not maintain physical custody of client assets, we are deemed to have custody Custody of certain client assets if given the authority to withdraw fees from client accounts (see , below). For our other clients, we do not accept custody of their assets. Regardless of whether we are deemed to have custody, client assets are maintained by a qualified custodian. Our firm seeks to recommend a custodian who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. The factors considered, among others, are these: • • • • • • • • • • • • • Timeliness of execution Timeliness and accuracy of trade confirmations Research services provided Ability to provide investment ideas Execution facilitation services provided Record keeping services provided Custody services provided Frequency and correction of trading errors Ability to access a variety of market venues Expertise as it relates to specific securities Financial condition Business reputation Quality of services With this in consideration, our firm has an arrangement with Fidelity Brokerage Services LLC (U.S.), Fidelity Clearing Canada (Canada), National Bank Independent Network (Canada), Charles Schwab & Co., Inc., Pershing LLC, and National Advisors Trust Company (“Our Custodians”), among other qualified custodians from whom our firm is independently owned and operated. Our Custodians offer services to independent investment advisers which includes custody of securities, trade execution, clearance and settlement of transactions. Our Custodians enable us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Our Custodians do not charge client accounts separately for custodial services. Client accounts will be charged transaction fees, commissions or other fees on trades that are executed or settle into the client’s custodial account. Transaction fees may be charged via individual transaction charges. These fees are negotiated with Our Custodians and are generally discounted from customary retail commission rates. This benefits clients because the overall fee paid is often lower than would be otherwise. Our Custodians may make certain research and brokerage services available at no additional cost to our firm. Research products and services provided by Our Custodians may include: research reports on recommendations or other information about particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Our Custodians to our firm in the performance of our 26  investment decision-making responsibilities. The aforementioned research and brokerage services qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of 1934. Our Custodians do not make client brokerage commissions generated by client transactions available for our firm’s use. The aforementioned research and brokerage services are used by our firm to manage accounts for which our firm has investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence our firm’s choice of Our Custodians as a custodial recommendation. Our firm examined this potential conflict of interest when our firm chose to recommend Our Custodians and has determined that the recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. Our clients may pay transaction fees or commissions to Our Custodians that are higher than another qualified broker dealer might charge to effect the same transaction where our firm determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services provided to the client as a whole. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. Soft Dollars Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The safe harbor research products and services obtained by our firm will generally be used to service all of our clients but not necessarily all at any one particular time. Client Transactions in Return for Soft Dollars Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Our firm does not receive brokerage for client referrals. Directed Brokerage Neither our firm nor any of our firm’s representatives have discretionary authority in making the determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Our firm routinely recommends that clients direct us to execute through specified broker-dealers. Our firm recommends the use of Our Custodians. Each client will be required to establish their account(s) with Our Custodians if not already done. Please note that not all 27  advisers have this requirement. Aggregation of Purchase or Sale Where Cardinal Point is able, Cardinal Point will purchase or sell the same securities for several clients at approximately the same time in its attempt to obtain “best execution”, to negotiate more favorable commission rates, or to allocate equitably among Cardinal Point’s clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple clients’ accounts so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading allows Cardinal Point to execute equity trades in a timelier, equitable manner and seeks to reduce overall commission charges to clients. As referenced in the section of this Disclosure Brochure that discusses directed brokerage, in the event that a client directs Cardinal Point to use a particular broker-dealer, Cardinal Point may not be able to “batch” the client’s transactions for execution through other broker-dealers with orders for other accounts managed by Cardinal Point. Trade Error On occasion, we may make an error in executing securities transactions for a client account. For example, a security may be erroneously purchased for the account instead of sold, or a trade may be entered for an incorrect number of shares. In these situations, our firm adheres to trade error policies and procedures that generally seek to rectify the error by placing the client account in a similar position as it would have been if there had been no error. Depending on the circumstances, and subject to applicable legal and contractual requirements, various corrective steps may be taken, including canceling the trade, correcting an allocation, or taking the trade into our trade error account and reimbursing the client account. Our firm generally does not consider errors that are corrected prior to settlement, errors committed by brokers or other third parties, or errors related to reporting, model portfolios or systems implementation to be trade errors. Item 13: Review of Accounts or Financial Plans We review accounts on at least a quarterly basis for our clients subscribing to our Portfolio Management services. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we meet with clients who subscribe to our Portfolio Management services. The Compliance Department conducts quarterly reviews of client accounts. We may review client accounts more frequently than described above. Among the factors which may trigger an off- cycle review are major market or economic events, the client’s life events, requests by the client, etc. Item 14: Client Referrals & Other Compensation We receive an economic benefit from our Custodians in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Our Custodians. These products and services, how they benefit us, and the related 28  conflicts of interest are described above (see Item 12 –Brokerage Practices). The availability to us of our custodian’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Cardinal Point’s parent company is Focus Financial Partners, LLC (“Fous”). Throughout the year, Focus, LLC holds partnership meetings and other industry and best-practices conferences, which typically include Cardinal Point, other Focus, LLC firms and external attendees. These meetings are first and foremost intended to provide training or education to personnel of Focus, LLC firms, including Cardinal Point. However, the meetings do provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus, LLC firms, including Cardinal Point. Although the participation of Focus, LLC firm personnel in these meetings is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and the access granted, at such meetings and conferences could cause Cardinal Point to focus on those conference sponsors in the course of its duties. Focus, LLC attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate, including Cardinal Point. Conference sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset placement. The following entities have provided conference sponsorship to Focus from January 1, 2025 to February 1, 2026: o o o o o o o o o o o o o o o o o o o o o o o o Addepar, Inc. AQR Capital Management, LLC Bigelow LLC BlackRock, Inc. BOWS Administrator LLC (Brookfield Oaktree Wealth Solutions) Capital Integration Systems LLC (CAIS) Charles Schwab & Co., Inc. Cliffwater LLC Dimensional Fund Advisors LP Dinsmore Compliance Services, LLC (DCS) Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates) Edgewood Partners Insurance Center (EPIC) (includes Vanbridge) Fidelity Brokerage Services LLC (includes FIAM and Wealthscape) Flourish Financial LLC Franklin Templeton Distributors LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and CANVAS) Jackson National Life Distributors LLC K&L Gates LLP Lord, Abbett & Co. LLC Nuveen Securities, LLC Orion Advisor Solutions, Inc. Pacific Investment Management Company LLC (PIMCO) Pinnacle Insurance & Financial Services, LLC Practifi, Inc. Quantinno Capital Management LP (includes TaxEdge and DEALS (Direct Equity Active Long Short)) 29  o o o o o o o RedBlack Software, LLC (includes intelliflo) SmartAsset Advisors LLC Stone Ridge Asset Management LLC The Vanguard Marketing Corporation, Inc. T. Rowe Price Investment Services, Inc. TriState Capital Bank VRGL Inc. You can access updates to the list of conference sponsors on Focus’ website through the following link https://www.focusfinancialpartners.com/conference-sponsors. Client Referrals Our firm provides cash or non-cash compensation directly or indirectly to unaffiliated person(s) and/or affiliated firm(s) for the referral of prospective clients to our firm in accordance with Rule 206(4)-1 of the Investment Advisers Act of 1940 (the “Advisers Act”). Such compensation arrangements will not result in higher costs to the referred client. In this regard, our firm maintains a written agreement with each unaffiliated person(s) and/or affiliated firm(s) that is compensated for testimonials or endorsements (which include client referrals) in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206(4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each referral: • • • Whether or not the unaffiliated person is a current client of our firm, A description of the cash or non-cash compensation provided directly or indirectly by our firm to the unaffiliated person(s) and/or affiliated firm(s) in exchange for the referral, if applicable, and A brief statement of any material conflicts of interest on the part of the unaffiliated person(s) and/or affiliated firm(s) giving the referral resulting from our firm’s relationship with such unaffiliated person(s) and/or affiliated firm(s). In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is paying solicitation fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. Item 15: Custody Deduction of Advisory Fees: While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further described below under “Third Party Money Movement”. All of our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. 30  Third Party Money Movement: On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to The Custody Rule. The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian: • • • • • • • instruction and an annual notice reconfirming the instruction. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. The client has the ability to terminate or change the instruction to the client’s qualified custodian. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. The client’s qualified custodian sends the client, in writing, an initial notice confirming the Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Item 16: Investment Discretion Cardinal Point’s portfolio management services are generally provided on a discretionary basis. Cardinal Point may also provide non-discretionary investment advice. Where Cardinal Point has discretionary management authority, Cardinal Point will be authorized to determine the securities to be bought or sold for the client’s account(s), the amount of securities to be brought or sold, and the broker or dealer to be used to execute client securities transactions. Each client may (but typically do not) request reasonable limitations on Cardinal Point’s discretionary authority, which the firm will consider on a case-by-case basis. The Portfolio Management Agreement, and the agreement between the client and the custodian/broker-dealer for the account, grant discretionary authority to Cardinal Point. The client’s written agreement with the custodian also grants a limited power of attorney to Cardinal Point to effect transactions in the client’s custodial account. 31  Item 17: Voting Client Securities As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm provides investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. A client may request a written copy of Cardinal Point’s policies and procedures relating to proxy voting by contacting Matthew Zienty in writing at Cardinal Point Capital Management, ULC., 3280 Bloor Street West, Centre Tower, Suite 500 Toronto, ON M8X 2X3. Item 18: Financial Information Inclusion of a Balance Sheet We are not required to provide financial information in this Brochure because we do not require the prepayment of more than $1,200 in fees and six or more months in advance and we do not have financial condition or commitment that impairs its ability to meet contractual and fiduciary obligations to clients. We have never been the subject of a bankruptcy proceeding. 32