CARL STUART INVESTMENT ADVISOR, INC.

Stuart Investment Advisors, Inc. d/b/a Stuart Investment Advisors Form ADV Part 2A – Disclosure Brochure Effective: April 30, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Stuart Investment Advisors, Inc. (“SIA” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (512) 478-2275. SIA is a registered investment advisor with U.S. Securities and Exchange Commission. The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about SIA to assist you in determining whether to retain the Advisor. Additional information about SIA and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 109995. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110 Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of SIA. For convenience, the Advisor has combined these documents into a single disclosure document. SIA believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. SIA encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on February 5, 2025: • The Advisor has changed its name to Stuart Investment Advisors, Inc. d/b/a Stuart Investment Advisors. • The Advisor now engages in borrowing transactions for certain client accounts. Please see Item 8 for additional information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 109995. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (512) 478-2275. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 2  Item 3 – Table of Contents Item 2 – Material Changes ...................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................... 3 Item 4 – Advisory Services ...................................................................................................................... 4 Item 5 – Fees and Compensation ........................................................................................................... 5 Item 6 – Performance-Based Fees and Side-By-Side Management ....................................................... 7 Item 7 – Types of Clients ......................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 7 Item 9 – Disciplinary Information ............................................................................................................. 9 Item 10 – Other Financial Industry Activities and Affiliations ................................................................... 9 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 9 Item 12 – Brokerage Practices .............................................................................................................. 10 Item 13 – Review of Accounts ............................................................................................................... 11 Item 14 – Client Referrals and Other Compensation ............................................................................. 11 Item 15 – Custody ................................................................................................................................. 12 Item 16 – Investment Discretion ............................................................................................................ 12 Item 17 – Voting Client Securities ......................................................................................................... 12 Item 18 – Financial Information ............................................................................................................. 12 Form ADV Part 2B – Brochure Supplement .......................................................................................... 13 Privacy Policy ........................................................................................................................................ 17 Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 3  Item 4 – Advisory Services A. Firm Information Stuart Investment Advisor, Inc. d/b/a Stuart Investment Advisors (“SIA” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission, which is organized as a Corporation under the laws of the State of Texas. SIA was founded in December 1997 and became registered with the SEC in May of 1999, and is owned and operated by Carl Stuart (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by SIA. B. Advisory Services Offered SIA offers investment advisory services to individuals, high-net-worth individuals, retirement plans, trusts, estates, charitable organizations and foundations, state and municipal government entities, and corporations. (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. SIA fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services SIA provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. SIA works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. SIA will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. SIA investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. SIA will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. SIA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. SIA may recommend, on occasion, redistributing investment allocations to diversify the portfolio. SIA may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. SIA may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 4  account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will SIA accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Plan Advisory Services SIA provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ● ● Investment Oversight Services (ERISA 3(21)) Investment Management Services (ERISA 3(38)) These services are provided by SIA serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of SIA fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging SIA to provide investment advisory services, each Client is required to enter into an agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – SIA, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – SIA will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – SIA will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – SIA will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs SIA does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by SIA. E. Assets Under Management As of December 31, 2024, SIA manages $515,188,081 in Client assets, $419,273,391 of which are managed on a discretionary basis and $95,914,690 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 5  A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly at the end of each three month period, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the three month period. Investment advisory fees are based on the following schedule: Assets Under Management ($) First $250,000 Next $250,001 to $1,000,000 Over $1,000,000 Annual Rate (%) 1.50% 1.00% 0.75% The investment advisory fee in the first three month period of service is prorated from the inception date of the account(s) to the end of the first period. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by SIA will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.50% and are billed in arrears, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of the three month period. Fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send a spreadsheet to the Custodian indicating the amount of the fees to be deducted from the Client’s account(s) at the end of the three month period. The amount due is calculated by applying the (number of days in the period divided by the number of days in the year) to the total assets under management with SIA at the end of the prior three month period. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by SIA to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Retirement Plan Advisory Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than SIA, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian. The fees charged by SIA are separate and distinct from these custody and execution fees. In addition, all fees paid to SIA for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 6  in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of SIA but would not receive the services provided by SIA which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by SIA to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Payment of Fees and Termination Investment Management Services SIA is compensated for its services in arrears of the quarter in which investment advisory services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services SIA is compensated for its services at the end of the three month period. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for retirement plan advisory fees up to and including the effective date of termination. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Item 6 – Performance-Based Fees and Side-By-Side Management SIA does not charge performance-based fees for its investment advisory services. The fees charged by SIA are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. SIA does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients SIA offers investment advisory services to individuals, high-net-worth individuals, retirement plans, trusts, estates, charitable organizations and foundations, state and municipal government entities, and corporations. The amount of each type of Client is available on SIA Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. SIA generally requires a minimum relationship size of $250,000 to effectively implement its investment process. SIA may wave the minimum at its sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis SIA employs a fundamental analysis method in developing investment strategies for its Clients. Research and analysis from SIA are derived from numerous sources, including financial media companies, third-party research materials, face to face visits with portfolio managers, Internet sources, and review of company activities, including annual reports, prospectuses, press releases, research prepared by others. As noted above, SIA generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. SIA will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, SIA may also Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 7  buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Clients should be prepared to bear the potential risk of loss. SIA will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with certain components of the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 8  i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving SIA or its owner. SIA values the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 109995. Item 10 – Other Financial Industry Activities and Affiliations The sole business of SIA and its Advisory Persons is to provide investment advisory services to its Clients. Neither SIA nor its Advisory Persons are involved in other business endeavors. SIA does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics SIA has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with SIA (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. SIA and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of SIA Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (512) 478-2275. B. Personal Trading with Material Interest SIA allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. SIA does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. SIA does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients SIA allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 9  trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by SIA requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. We have also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While SIA allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will SIA, or any Supervised Person of SIA, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] SIA does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize SIA to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, SIA does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade- by-trade basis. While SIA does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by SIA. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. SIA may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. SIA will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc. (“Raymond James”) member New York Stock Exchange/SIPC, a FINRA-registered broker-dealer. Raymond James will serve as the Client’s “qualified custodian”. SIA maintains an institutional relationship with Raymond James, whereby the Advisor receives economic benefits from Raymond James. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. SIA does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - SIA does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where SIA will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). SIA will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 10  B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. SIA will execute its transactions through the Custodian as authorized by the Client. SIA may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Carl Stuart, Chief Compliance Officer of SIA. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify SIA if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by SIA Participation in Institutional Advisor Platform SIA has established an institutional relationship with Raymond James & Associates, Inc. (“Raymond James or Custodian”) member New York Stock Exchange/SIPC to assist the Advisor in managing Client account[s]. Access to the Raymond James platform is provided at $750 per month charge to the Advisor. The Advisor receives access to software and related support at a reduced cost because the Advisor renders investment management services to Clients that maintain assets at Raymond James. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. B. Compensation for Client Referrals SIA does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 11  Item 15 – Custody SIA does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom SIA exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct SIA to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by SIA to ensure accuracy, as the Custodian does not perform this review. Money Movement Authorization - For instances where Clients authorize SIA to move funds between their accounts, SIA and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion SIA generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by SIA. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by SIA will be in accordance with each Client's investment objectives and goals. In certain engagements, SIA does not have discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior approval from the Client. The Advisor will contact the Client and obtain approval prior to executing trades or allocating investment assets. Item 17 – Voting Client Securities SIA does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither SIA, nor its management, have any adverse financial situations that would reasonably impair the ability of SIA to meet all obligations to its Clients. Neither SIA, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. SIA is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 12  Form ADV Part 2B – Brochure Supplement for Carl W. Stuart President Effective: April 30, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Carl W. Stuart (CRD# 860980) in addition to the information contained in the Stuart Investment Advisors, Inc. (“SIA” or the “Advisor”, CRD# 109995) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the SIA Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (512) 478-2275. Additional information about Mr. Stuart is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 860980. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 13  Item 2 – Educational Background and Business Experience Carl W. Stuart, born in 1947, is dedicated to advising Clients of SIA as the President. Mr. Stuart earned his degree in Political Science and Government from The University of Iowa in 1969. Additional information regarding Mr. Stuart’s employment history is included below. Employment History: President, Stuart Investment Advisors, Inc. d/b/a Stuart Investment Advisors Registered Representative, Raymond James Financial Services Advisors, Inc. 02/1998 to Present 12/1997 to 06/2020 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Stuart. Mr. Stuart has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Stuart. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Stuart. However, we do encourage you to independently view the background of Mr. Stuart on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 860980. Item 4 – Other Business Activities Mr. Stuart is dedicated to the investment advisory activities of SIA Clients. Mr. Stuart does not have any other business activities. Item 5 – Additional Compensation Mr. Stuart has an additional business activity detailed in Item 4 above. Mr. Stuart does not receive any compensation from this activity. Item 6 – Supervision Mr. Stuart serves as the President and Chief Compliance Officer of SIA. Mr. Stuart can be reached at (512) 478- 2275. SIA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of SIA. Further, SIA is subject to regulatory oversight by various agencies. These agencies require registration by SIA and its Supervised Persons. As a registered entity, SIA is subject to examinations by regulators, which may be announced or unannounced. SIA is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 14  Form ADV Part 2B – Brochure Supplement for Lindsey B. Stuart Investment Advisor Effective: April 30, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Lindsey B. Stuart (CRD# 7688688) in addition to the information contained in the Stuart Investment Advisors, Inc. (“SIA” or the “Advisor”, CRD# 109995) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the SIA Disclosure Brochure or this Brochure Supplement, please contact us at (512) 478-2275. Additional information about Ms. Stuart is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7688688. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 15  Item 2 – Educational Background and Business Experience Lindsey B. Stuart, born in 1980, is dedicated to advising Clients of SIA as an Investment Advisor. Ms. Stuart earned a Bachelor of Arts in Spanish from Wellesley College in 2002. She later earned two Master’s degrees: a Masters of Arts, Teaching from American University in 2006 and a Master of Public Affairs from University of Texas at Austin, LBJ School of Public Affairs in 2010. Additional information regarding Ms. Stuart’s employment history is included below. Employment History: 01/2023 to Present 11/2013 to 12/2022 Investment Advisor, Stuart Investment Advisor, Inc. d/b/a Stuart Investment Advisors Director, Office of Innovation and Development, Austin Independent School District Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Ms. Stuart. Ms. Stuart has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Ms. Stuart. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Ms. Stuart. However, we do encourage you to independently view the background of Ms. Stuart on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7688688. Item 4 – Other Business Activities Ms. Stuart is dedicated to the investment advisory activities of SIA Clients. Ms. Stuart does not have any other business activities. Item 5 – Additional Compensation Ms. Stuart is dedicated to the investment advisory activities of SIA Clients. Ms. Stuart does not receive any additional forms of compensation. Item 6 – Supervision Ms. Stuart serves as an Investment Advisor of SIA and is supervised by Carl Stuart, the Chief Compliance Officer. Mr. Stuart can be reached at (512) 478-2275. SIA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of SIA. Further, SIA is subject to regulatory oversight by various agencies. These agencies require registration by SIA and its Supervised Persons. As a registered entity, SIA is subject to examinations by regulators, which may be announced or unannounced. SIA is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 16  Privacy Policy Effective: April 30, 2025 Our Commitment to You Stuart Investment Advisor, Inc. (“SIA” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. SIA (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. SIA does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 17  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Marketing Purposes SIA does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where SIA or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). No Not Shared Information About Former Clients SIA does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (512) 478-2275. Stuart Investment Advisors, Inc. 623 W 38th Street, Suite 110, Austin, TX 78705 Phone: (512) 478-2275 * Fax: (512) 478-3062 Page 18