CHARTER ADVISORY CORPORATION

Charter Advisory Corporation Form ADV Part 2A Brochure CoverPage Charter Advisory Corporation 250 E. 96th Street, Suite 200, Indianapolis, IN 46240 (317)844-7416 www.charteradvisory.com March 24, 2026 This Brochure provides information about the qualifications and business practices of Charter Advisory Corporation. If you have any questions about the contents of this Brochure, please contact Michael J. Kelley at (317) 844-7416 or via email at mkelley@charteradvisory.com. 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. Charter Advisory Corporation is an SEC Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Charter Advisory Corporation is also available on the SEC’s website at www.adviserinfo.sec.gov. i  Charter Advisory Corporation Form ADV Part 2A Brochure Material Changes In the past we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to new SEC Rules, we will ensure that you receive a summary of any materials changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. Investment advisors must update the information in their firm brochure at least annually. In lieu of providing clients with an updated brochure each year, we will provide Charter Advisory Corporation’s existing advisory clients with this summary page describing any material changes since the last annual update of the brochure. We will deliver a brochure or summary each year to existing clients within 120 days of the close of Charter Advisory Corporation’s fiscal year. Clients wishing to receive a complete copy of the current brochure may request a brochure by contacting Michael J. Kelley at (317) 844-7416 or via email at mkelley@charteradvisory.com. We have no material changes from the prior brochure dated March 20, 2025. Additional information about Charter Advisory Corporation is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Charter Advisory Corporation who are registered, or are required to be registered, as investment adviser representatives of Charter Advisory Corporation. ii  Charter Advisory Corporation Form ADV Part 2A Brochure Table of Contents Cover Page .................................................................................................................................................. i Material Changes ......................................................................................................................................... ii Table of Contents ......................................................................................................................................... iii Advisory Business .......................................................................................................................................... 4 Fees and Compensation ................................................................................................................................. 8 Performance-Based Fees and Side-By-Side Management .......................................................................... 12 Types of Clients ........................................................................................................................................... 12 Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................... 13 Disciplinary Information ............................................................................................................................. 14 Other Financial Industry Activities and Affiliations.................................................................................... 14 Code of Ethics .............................................................................................................................................. 16 Brokerage Practices .................................................................................................................................... 18 Review of Accounts ...................................................................................................................................... 21 Client Referrals and Other Compensation .................................................................................................. 22 Custody ........................................................................................................................................................ 22 Investment Discretion .................................................................................................................................. 23 Voting Client Securities ............................................................................................................................... 23 Class Action Lawsuits .................................................................................................................................. 23 Financial Information .................................................................................................................................. 23 Brochure Supplement(s) iii  Charter Advisory Corporation Form ADV Part 2A Brochure Advisory Business Charter Advisory Corporation (hereinafter “Charter”), offers personalized investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Charter’s services and fee arrangements are described in the following pages. Charter is a corporation formed under the laws of the State of Indiana. Charter has been conducting advisory services since 1979. Michael J. Kelley is the principal owner and President of Charter Advisory Corporation. This narrative provides clients with information regarding Charter and the qualifications, business practices, and nature of advisory services that should be considered before becoming an advisory client of Charter. Individuals associated with Charter will provide its investment advisory services. These individuals are authorized to provide advisory services on behalf of Charter. Such individuals are known as Investment Adviser Representatives (IARs). IARs with Charter are registered representatives of LPL Financial, a licensed full service securities broker/dealer and investment adviser under federal and state securities laws, located in Boston, Massachusetts. LPL Financial is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investors Protection Corporation (“SIPC”). Securities transactions for LPL's brokerage clients are executed through LPL. Charter is not an affiliate of LPL Financial. Financial Planning Services Financial planning services will typically involve providing a variety of services, principally advisory in nature, to clients regarding the management of their financial resources based upon an analysis of their individual needs. Charter works with a variety of clients to assist them with their long and short term financial planning. Charter focuses on the preparation of financial plans, which provide a framework and structure for combining client goals with current and future savings and retirement programs. It also works on a contract basis to assist clients in decisions concerning their investments, insurance and other related accounts. Charter relies on responses provided by clients to questionnaires and interviews, as well as copies of supporting documentation and/or data provided by the client or its lawyer, accountant or other advisers. Implementation of the prepared plan or recommendations is solely at the discretion of the client, with the client also determining how he/she will implement the plan or recommendations. The client is encouraged to utilize any desired professional or group of professionals to assist in implementation. 4  Charter Advisory Corporation Form ADV Part 2A Brochure Charter’s Investment Advisory Services Charter provides investment advisory services to its clients on a discretionary and non- discretionary basis. The advisory services include, among other things, providing advice regarding asset allocation and the selection of investments. Account management is guided by the stated objectives of the client. In addition, the Adviser considers the client’s risk profile and financial status prior to making any recommendations. LPL Financial Sponsored Advisory Programs Charter may provide advisory services to clients through certain programs sponsored by LPL Financial (LPL), a registered investment adviser and broker/dealer. Below is a brief description of each LPL advisory program available to Charter. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. LPL Advisory Services Manager Access Select Program (“MAS”) MAS offers clients the ability to participate in the Separately Managed Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”). In the SMA Platform, Charter will assist client in identifying a third party portfolio manager (“SMA Portfolio Manager”) from a list of SMA Portfolio Managers made available by LPL, and the SMA Portfolio Manager manages client’s assets on a discretionary basis. Charter will provide initial and ongoing assistance regarding the SMA Portfolio Manager selection process. In the MP Platform, clients authorize LPL to direct the investment and reinvestment of the assets in their accounts, in accordance with the selected model portfolio provided by LPL’s Research Department or a third-party investment adviser. Clients should review the MAS Program Brochure for more detailed information, available at lpl.com/disclosures.html. A minimum account value of $50,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. 5  Charter Advisory Corporation Form ADV Part 2A Brochure Optimum Market Portfolios Program (OMP) OMP is a professionally managed mutual fund asset allocation program in which LPL and Charter provide ongoing investment advice and management. Charter obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. Charter selects a model portfolio of mutual funds comprised of Optimum Funds Class I shares, designed by LPL’s Research Department consistent with the client’s stated investment objective. Clients grant LPL discretionary trading authority to sell previously purchased securities and purchase and sell Optimum Funds to track the model portfolio. Clients should review the OMP Program Brochure for more detailed information, available at lpl.com/disclosures.html. LPL generally requires a minimum account value of $1,000 for OMP, but additional contributions may be required for account sizes below $10,000. In certain instances, LPL will permit a lower minimum account size. Personal Wealth Portfolios Program (PWP) PWP is a unified managed account program in which LPL and Charter provide ongoing investment advice and management to clients. Charter obtains the necessary financial data from the client and assists the client in setting an appropriate investment objective. Client authorizes Charter on a discretionary basis to select an asset allocation model portfolio designed by LPL (“Portfolio”). Charter then selects third party investment advisers (“PWP Advisors”) who will provide investment models within each asset class of the Portfolio. Clients authorize LPL to invest in accordance with the portfolio and models. Clients should review the PWP Program Brochure for more detailed information, available at lpl.com/disclosures.html. A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP is a unified managed account program in which LPL and Charter provide ongoing investment advice on a discretionary basis. Charter obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. Charter selects one or more model portfolios of securities (each, a “Portfolio”) designed by LPL’s Research Department, a third-party investment strategist, or Charter (each, a “Portfolio Strategist”), consistent with the client’s stated investment objective. These Portfolios may contain mutual funds, ETFs, exchange-traded notes (“ETNs”), closed-end funds, equities, or fixed-income securities. Charter provides ongoing advice on the selection or 6  Charter Advisory Corporation Form ADV Part 2A Brochure replacement of a Portfolio based on the client’s individual needs and may choose more than one Portfolio to be managed within a single MWP account. A Portfolio also may be comprised of one or more underlying models. Clients grant Charter discretion to choose among the available models designed by the Portfolio Strategists, which may include Charter and its IARs. The Portfolio Strategist is responsible for selecting the securities within a Portfolio and for making changes to the securities selected. Each Portfolio Strategist provides its model portfolio to LPL, and LPL makes the decisions on how to implement the model on behalf of clients. Clients should review the MWP Program Brochure for more detailed information, available at lpl.com/disclosures.html. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $10,000. In certain instances, a lower minimum for a portfolio is permitted. Client understands that the account will not be invested according to a model portfolio until the applicable asset minimums for that model portfolio have been reached. Guided Wealth Portfolios (GWP) GWP is an advisor-enhanced digital advice program that offers clients the ability to participate in a centrally managed investment program, which is made available to users and clients through a web-based, interactive account management portal. Clients are required to maintain an active profile in the account management portal to participate in the program. Clients select from one of the following goals for their account: retirement, major purchase, or general investing. Based on information provided by the client, the client is assigned a model portfolio constructed by LPL. Charter determines the suitability of the Program for the client and an appropriate investment allocation track for the client. Clients authorize LPL on a discretionary basis to purchase and sell securities based upon the model portfolio. Program securities currently include a limited universe of ETFs but may include mutual funds in the future. Clients should review the GWP Program Brochure for more detailed information, available at lpl.com/disclosures.html. A minimum account value of $5,000 is required to enroll in GWP. Solicitation/ Referral Services to Sponsored Programs Directly Managed Programs In directly managed programs, Charter will refer clients to independent, third-party investment advisers (TPIA). The TPIA manages the client's account in accordance with the disclosures set forth in the third-party investment adviser's documents. Charter is engaged by the TPIA to provide referral services on behalf of the TPIA pursuant to an agreement between Charter and the TPIA. Charter is compensated by the TPIA for referring the clients. The TPIA may assume discretionary authority over the assets in the accounts participating in these programs. 7  Charter Advisory Corporation Form ADV Part 2A Brochure Charter provides the following services on behalf of the TPIA. Charter typically gathers information from the client about the client's financial situation, investment objectives, and reasonable restrictions the client wants to impose on the management of the account. Charter then periodically reviews reports provided to the client; contacts the client at least annually to review the client's financial situation and objectives; communicates information to the third-party investment adviser as warranted; and assists the client in understanding and evaluating the services provided by the third-party adviser that is directly managing the account. ERISA Plan Services Charter 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 plan clients, including ERISA plan participants. Charter is also a fiduciary under the Internal Revenue Code (IRC) with respect to investment management services and investment advice provided to ERISA plans, ERISA plan participants, IRAs and IRA owners (collectively, “Retirement Account Clients”). As such, Charter is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (PTE). Charter manages assets on a discretionary or nondiscretionary basis. As of December 31, 2025, Charter managed $333,085,121 of client assets of which, $275,846,221 in 861 accounts are managed on a discretionary basis and $57,238,900 in 16 accounts are managed on a non- discretionary basis. Fees and Compensation Financial Planning Clients are charged fees by Charter based upon the complexity and estimated hours of worked needed to prepare the plan. No advance or deposit is required unless specified for larger projects. If a deposit is required, fees are payable one half at the time of execution of a written agreement retaining Charter to prepare the plan, with a maximum amount of $1,200 paid at this time. The remainder of fees is due upon receipt of the plan by the client. Additional work requested by the client beyond preparation of the plan is billed at a rate ranging from $45 to $300 per hour, payable upon completion of the work. 8  Charter Advisory Corporation Form ADV Part 2A Brochure Charter also provides investment advice on isolated transactions for individuals who are not otherwise clients. This service consists of consultations generally followed by written recommendations regarding the specified transaction(s). Fees for this service include a minimum of $325, with additional charges of $125 to $300 per hour for the fourth and subsequent hour thereafter. The client may terminate a financial planning agreement within five business days after the date when all parties have signed the agreement without penalty. After this five-day period, either party may terminate the agreement upon written notice to the other. The client will incur a prorated charge for bona fide financial planning and/or consulting services rendered prior to such termination. Accordingly, any unearned, pre-paid fees will be returned to the client promptly. Charter’s Investment Advisory Services Fees Management fees are paid quarterly in advance. Fees are due on the first day of the billing quarter, and may be billed directly to the client or deducted from the advisory account. Fees are based on the account’s asset value as of the last business day of the prior billing quarter and are prorated for accounts opened during the quarter. Fees are negotiable and will be reviewed with each client to discuss the scope prior to entering into an agreement. An advisory client will have a period of five (5) business days from the date of signing the investment management agreement to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, either party may terminate the agreement with 30 days written notice. The account custodian may charge fees, which are in addition to and separate from the investment advisory service fee. Custodians may charge accounts for various transaction costs, retirement plan and administration fees. In addition, some mutual fund assets deposited in the account may have been subject to deferred sales charges and 12b (1) fees and other mutual fund annual expenses as described in each fund’s prospectus. Advisory clients should also note that fees for comparable services vary and may be considered in excess of industry norm. Lower fees for comparable services may be available from other sources. 9  Charter Advisory Corporation Form ADV Part 2A Brochure Fees for LPL Advisory Program The account fee charged to the client for each LPL advisory program is negotiable, subject to the following maximum account fees: Manager Access Select 2.95% * OMP PWP MWP GWP 2.5% 2.95% ** 2.95%*** 1.35%**** * The Manager Access Select (“MAS”) account fee consists of an advisory fee of up to 2.35% annually and a manager fee of up to 0.60%. See the MAS program brochure for more information. ** The PWP account fee consists of an advisory fee of up to 2.35% annually and a manager fee of up to 0.60%. See the PWP program brochure for more information. *** The MWP account fee consists of an advisory fee of up to 2.35% and a manager fee of up to 0.60%. See the MWP program brochure for more information. **** GWP clients are charged an account fee consisting of an LPL program fee of 0.35% and an advisor fee of up to 1.00%. LPL Research currently serves as the sole portfolio strategist and does not charge a fee for its services. Account fees are payable quarterly in advance. LPL serves as program sponsor, co-investment adviser and broker-dealer for the LPL advisory programs. Charter and LPL may share in the account fee and other fees associated with program accounts. Associated persons of Charter may also be registered representatives of LPL. Conflicts of Interest Charter receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, the ability to negotiate fees or commissions, the historical or expected size or number of transactions, and the number and range of supplementary advisory and client- related services provided to the client, the amount of this compensation may be more or less than what the Advisor would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. 10  Charter Advisory Corporation Form ADV Part 2A Brochure The account fee may be higher than the fees charged by other investment advisers for similar services. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with Charter. Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of conflicts of interest for each LPL Financial sponsored advisory program. Fee Billing for LPL custodied advisory accounts For advisory accounts custodied at LPL, unless otherwise instructed by Charter, LPL will deduct Advisor’s fee quarterly in advance; however, for the initial fee deduction, LPL will deduct the Advisor’s fee at the beginning of the quarter following the establishment of the Account and will include a prorated fee for the initial quarter in addition to the quarterly Advisor fee for the upcoming quarter. Subsequent fee deductions will be made at the beginning of each quarter based on the value of the Account assets as of the close of business on the last business day of the preceding quarter. Additional deposits and withdrawals will be added or subtracted from the assets, which may lead to an adjustment of the Advisor’s fee. If LPL is notified by Charter or the client of the termination or deactivation of the Account’s advisory account status at LPL, LPL will process a prorated refund of Advisor’s fees that were prepaid based upon the number of days remaining in the quarter after the notice of termination to LPL. Solicitation/ Referral Services to Sponsored Programs Directly Managed Programs Fees for these services may be negotiated between Charter and the TPIA. Fees for these services may be negotiated, but generally range from .75% to 3.0%, depending upon the program selected, the size of the account and the services covered. Under some programs, an all-inclusive fee covers account management, brokerage, clearance, custody, and administrative services. In other programs the account may be charged separately for such services. The amount of the fees, the services provided, the payment structure, termination provisions and other aspects of each program are detailed and disclosed in the third party investment adviser's Part 2A of Form ADV, the program's wrap fee disclosure Brochure (if applicable), or other applicable disclosure document, and in the account opening documents. Charter will share in the fee charged by the third party adviser. 11  Charter Advisory Corporation Form ADV Part 2A Brochure Clients receive an account statement at least quarterly, which includes the amount of any fees paid directly to the third party investment adviser. IARs of Charter, or the third party investment adviser may act as broker in connection with the program and may receive additional compensation in the form of commissions. Advice offered by Charter may involve investment in mutual funds. Clients are hereby advised that all fees paid to Charter for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. Further, there may be transaction charges involved with purchasing or selling of securities. Charter does not share in any portion of the brokerage fees/transaction charges imposed by the custodian holding the client funds or securities. The client should review all fees charged by mutual funds, Charter, and others to fully understand the total amount of fees to be paid by the client. Performance-Based Fees and Side-By-Side Management The fees charged are calculated in the previous Fee and Compensation section, and are not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client (15 U.S.C. §80b-5(a)(1 )). Types of Clients Charter offers personalized investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Investments in the Charter Investment Advisory Services program do not require a minimum account size, however minimum account sizes may be required by the custodian of the model portfolio selected as disclosed in this brochure. LPL OMP: this program generally has a minimum account size of $1,000; note that accounts below $10,000 are required to have annual or recurring contributions in place LPL PWP: this program generally has a minimum account size of $250,000. LPL MWP: this program generally has a minimum account size of $10,000. LPL Manager Access Select: this program has a minimum account size of $50,000, however, in certain instances; the minimum account size may be lower or higher. 12  Charter Advisory Corporation Form ADV Part 2A Brochure Methods of Analysis, Investment Strategies and Risk of Loss Charter will evaluate securities based on a fundamental or technical analysis using charts or cyclical studies. Fundamental analysis is a method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. The primary risk of fundamental analysis is that estimates of intrinsic value might be incorrect. Technical analysis is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. The primary risk of Technical analysis is that past market performance is not always an indicator of future market performance. Each client will meet with Charter to discuss the specific investment strategy to be used such as long term purchases, short term purchases, trading (securities sold within 30 days), margin and option trades. Charter may advise its investment advisory clients on other partnership investments such as mining – precious metals, agricultural business, cable TV, equipment leasing and/or venture capital. Securities and other types of investments all involve different types and levels of risk that the client should be prepared to bear. Frequent trading can effect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investment risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their accounts. Clients must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with clients, Charter attempts to identify the balance of risks and rewards that is appropriate and comfortable for the client. It is still the client’s responsibility to ask questions if he or she does not fully understand the risks associated with any investment. Clients are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. Charter cannot assure clients that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. 13  Charter Advisory Corporation Form ADV Part 2A Brochure Disciplinary Information Investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Charter or the integrity of Charter’s management. Charter has no information applicable to this Item. Other Financial Industry Activities and Affiliations IARs of Charter are separately licensed as registered representatives of LPL Financial. Some IARs of Charter are also dually registered as IARs of LPL. LPL Financial is a broker-dealer, member FINRA/SIPC and an SEC registered Investment Advisor that is independently owned and operated and is not affiliated with Charter. In this capacity, associated persons are involved in the sale of securities of various types, including, but not limited to stocks, bonds, mutual funds, variable annuities, and limited partnerships. In addition, associated persons may also be involved in the sale of insurance products. As such, associated persons can effect transactions in insurance products for clients and earn commissions for these activities. All compensation received by IARs of Charter for securities transactions through LPL Financial will be separate, yet customary for effecting securities transactions, including 12b-1 fees for the sale of investment company products. IARs may make differing recommendations with respect to the same securities or insurance products to different advisory clients. All recommendations made are specific to each client’s individualized needs and current financial situation. IARs, in their function as registered representatives and/or insurance agents, will effect securities transactions through LPL Financial. If an advisory client implements recommendations made by the associated person by purchasing securities or other products through LPL Financial, the associated person will receive additional compensation in the form of commissions, including 12b- 1 fees for the sale of investment company products. Certain IARs of Charter may offer pension planning services or be licensed as a CPA and/or an insurance agent with unaffiliated accounting firms and/or insurance agencies. Compensation may be received for these services, including fees for pension planning services, accounting services performed and commissions on insurance products provided. As part of their practice, financial recommendations may be made to clients of Charter by the Pension Consultant, CPA and/or insurance agent. Charter's clients are advised that they are under no obligation to act on these recommendations and have total freedom to implement recommendations through any investment advisor of their choosing. 14  Charter Advisory Corporation Form ADV Part 2A Brochure If the client implements recommendations made by an IAR of Charter by purchasing securities through LPL Financial, the IAR of Charter, in their separate capacity as a registered representative of LPL Financial, may receive additional compensation in the form of commissions, including 12b- 1 fees for the sale of investment company products. Charter's clients are advised that they have total freedom to implement recommendations through any broker/dealer of their choosing. In addition, from time to time, IARs of Charter may receive 12b-1 distribution fees from investment companies (mutual funds) in connection with the placement of client funds into investment companies through their separate capacities as registered representatives of LPL. IARs will also sell insurance products and will receive income for the sale of such products. Please refer to the Brokerage Practices section of this brochure for a discussion of additional benefits Charter may receive from LPL Financial and the conflicts of interest associated with receipt of such benefits. Charter will refer clients to independent, third party investment advisors (TPIA). Charter is engaged by the TPIA to provide referral services on behalf of the TPIA pursuant to an agreement between Charter and the TPIA. Charter is compensated by the TPIA for referring the clients. Fees for these services may be negotiated between Charter and the TPIA. Charter will share in the fee charged by the third party adviser. IARs of Charter, or the third party investment adviser may act as broker in connection with the program and may receive additional compensation in the form of commissions. The amount of the fees, the services provided, the payment structure, termination provisions and other aspects of each program are detailed and disclosed in the third party investment adviser's Part 2A of Form ADV, the program's wrap fee disclosure Brochure (if applicable), or other applicable disclosure document, and in the account opening documents. In addition, clients receive an account statement at least quarterly, which includes the amount of any fees paid directly to the third party investment adviser. As part of their fiduciary duty, Charter, and its associated persons endeavor at all times to put the interest of the client first. Clients should be aware that receipt of additional compensation itself creates a conflict of interest. 15  Charter Advisory Corporation Form ADV Part 2A Brochure Code of Ethics IARs of Charter may purchase the same securities or other products recommended to clients for their own account. At no time will such a transaction be of such a size to influence the market for the security. Records of any such transactions are available for review. Charter or individuals associated with Charter may buy or sell – for their personal account(s) - investment products identical to those recommended to clients. As these situations may represent a conflict of interest, Charter has established a code of ethics, the full text of which is available upon request; and it includes the following restrictions in order to ensure Charter’s fiduciary responsibilities: Charter emphasizes the unrestricted right of the client to specify investment objectives, • guidelines, and/or conditions on the overall management of their account. • Associated persons or their immediate family members shall not buy or sell securities for their personal portfolio(s) where their decision is derived in whole or in part, because of the associated person’s employment, unless the information is also available to the investing public on reasonable inquiry. • No associated person of Charter shall prefer his or her own interest to that of the advisory client. Where suitable, investment opportunities must be offered first to clients before Charter or associated persons may participate in such transactions. Charter requires that all individuals must act in accordance with all applicable federal and • state regulations governing registered investment advisory practices. • Any individual not in observance of the above may be subject to termination. Charter also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by Charter or any associated person. Charter’s clients or prospective clients may request a copy of Charter’s Code of Ethics by contacting Michael J. Kelley at (317) 844-7416 or via email at mkelley@charteradvisory.com. It is Charter’s policy that Charter will not affect any principal or agency cross securities transactions for client accounts. Charter will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal 16  Charter Advisory Corporation Form ADV Part 2A Brochure for its own account or the account of an affiliated broker/dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker/dealer or has an affiliated broker/dealer. Privacy Policies Charter views protecting its clients’ private information as a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act, Charter has instituted policies and procedures to ensure that client information is kept private and secure. Charter does not disclose any nonpublic personal information about its clients or former clients to any nonaffiliated third parties, except as permitted by law. In the course of servicing a client’s account, Charter may share some information with its service providers, such as transfer agents, custodians, accountants, lawyers, and withbroker-dealer firms having regulatory requirements to supervise certain activities of Charter’s representatives who are also registered with a broker-dealer firm. Charter restricts internal access to nonpublic personal information about the client to those employees who need to know that information in order to provide products or services to the client. As emphasized above, it has always been and will always be Charter’s policy never to sell information about current or former clients or their accounts to anyone. It is also Charter’s policy not to share information unless required to process a transaction, at the request of a client, or as required by law. Use of External Custodians As discussed previously, certain associated persons of Charter are registered representatives of LPL Financial. As a result of this relationship, LPL Financial may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about Charter’s clients in order to supervise certain activities of Charter’s Advisors, even if client does not establish any account through LPL. If you would like a copy of the LPL Financial privacy policy, please contact Charter at . 17  Charter Advisory Corporation Form ADV Part 2A Brochure Brokerage Practices Charter will recommend that a client in need of brokerage and custodial services utilize LPL Financial. Client may be able to obtain lower commissions and fees from other brokers. Investment adviser representatives of Charter are also associated with LPL Financial as broker- dealer registered representatives (“Dually Registered Persons”). In their capacity as registered representatives of LPL Financial, certain Dually Registered Persons may earn commissions for the sale of securities or investment products that they recommend for brokerage clients. They do not earn commissions on the sale of securities or investment products recommended or purchased in advisory accounts through Charter. Clients have the option of purchasing many of the securities and investment products we make available to you through another broker-dealer or investment adviser. However, when purchasing these securities and investment products away from Charter, you will not receive the benefit of the advice and other services we provide. While LPL Financial does not participate in, or influence the formulation of, the investment advice Charter provides, certain supervised persons of Charter are Dually Registered Persons. Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or executing client transactions in such client accounts through any broker-dealer or custodian that is not approved by LPL Financial. As a result, Charter reserves the right not to accept a client account if the client chooses to select a broker or dealer other than LPL Financial. Clients should also be aware that for accounts where LPL Financial serves as the custodian, Charter is limited to offering services and investment vehicles that are approved by LPL Financial, and may be prohibited from offering services and investment vehicles that may be available through other broker-dealers and custodians, some of which may be more suitable for a client’s portfolio than the services and investment vehicles offered through LPL Financial. Clients should understand that not all investment advisers require that clients custody their accounts and trade through specific broker-dealers. As stated previously, individuals associated with Charter are licensed as registered representatives of LPL Financial. As a result of this licensing relationship, LPL Financial is responsible for supervising certain activities of Charter to the extent Charter manages assets at a broker/dealer and custodian other than LPL Financial. LPL Financial charges a fee of up to 10 basis points to Charter for this oversight. This presents a conflict of interest in that Charter has a financial incentive to recommend that you maintain your account with LPL Financial rather than another custodian in 18  Charter Advisory Corporation Form ADV Part 2A Brochure order to avoid the oversight fee. However, to the extent Charter recommends you use LPL Financial for such services, it is because Charter believes that it is in your best interest to do so based on the quality and pricing of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services provided by LPL Financial. Benefits of Using LPL as Custodian1 Charter receives support services and/or products from LPL Financial, many of which assist Charter to better monitor and service program accounts maintained at LPL Financial; however, some of the services and products benefit Charter and not client accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate. Such compensation provided to Charter includes other types of compensation, such as bonuses, awards or other things of value offered by LPL to Charter, and may include the following:  Payments based on production;  Equity awards from LPL’s parent company, LPL Financial Holdings Inc., consisting of awards of either restricted stock units or stock options to purchase stock, in each case subject to satisfaction of vesting and other conditions;  Reimbursement or credit of fees that [Advisor] pays to LPL for items such as administrative services or technology fees;  Free or reduced-cost marketing materials;  Payments in connection with the transition of association from another broker- dealer or investment advisor firm to LPL;  Payments in the form of repayable or forgivable loans;  Advances of advisory fees; and/or  Attendance at LPL conferences and events. LPL Financial may provide these services and products directly or may arrange for third party vendors to provide the services or products to Advisor. In the case of third party vendors, LPL Financial may pay for some or all of the third party’s fees. These support services are provided to Charter based on the overall relationship between Charter and LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements with LPL Financial that involves the execution of client transactions as a condition 19  Charter Advisory Corporation Form ADV Part 2A Brochure to the receipt of services. Charter will continue to receive the services regardless of the volume of client transactions executed with LPL Financial. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by Charter to LPL or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. However, because Charter receives these benefits from LPL Financial, there is a potential conflict of interest. The receipt of these products and services presents a financial incentive for Charter to recommend that its clients use LPL Financial’s custodial platform rather than another custodian’s platform. For a further listing of potential conflicts, please refer to LPL Financial’s Brokerage Compensation and Conflicts Disclosure, available at lpl.com/disclosures.html. Transition Assistance LPL also provides various benefits and/or payments to Advisors that are new to the LPL platform to assist them with the costs (including foregone revenues during account transition) associated with transitioning their business to LPL (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the Advisor’s business, satisfying any outstanding debt owed to the Advisor’s prior firm, offsetting account transfer fees (ACATs) as a result of the Advisor’s clients transitioning to LPL’s custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. The amount of the Transition Assistance payments is often significant in relation to the overall revenue earned or compensation received by the Advisor at their prior firm. Such payments are generally based on the size of the Advisor’s business established at the prior firm. These payments are generally in the form of payments or loans to the Advisor with favorable interest rate terms as compared to other lenders, which are paid by LPL or forgiven by LPL based on years of service with LPL (e.g., if the Advisor remains with LPL for 5 years) and/or the scope of business engaged in with LPL. LPL does not verify that any payments made are actually used for such transition costs. The receipt of Transition Assistance creates a conflict of interest in that Advisor has a financial incentive to recommend that a client open and maintain an account with Charter and LPL for advisory, brokerage and/or custody services, and to recommend switching investment products or 20  Charter Advisory Corporation Form ADV Part 2A Brochure services where a client’s current investment options are not available through LPL, in order to receive the Transition Assistance benefit or payment, and in cases of businesses not supported by LPL, to further recommend that a client’s current holdings be reinvested in a program offering LPL does support. LPL and Charter Advisor’s attempt to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the Transition Assistance earned by any particular Advisor. However, clients should be aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with LPL. If LPL makes a loan to the Advisor, there is also a conflict of interest because LPL’s interest in collecting on the loan affects its ability to objectively supervise the registered representatives. Review of Accounts The IAR reviews the client’s portfolio periodically by reviewing all security positions held by clients under the IAR’s supervision. Triggering factors of additional reviews may include changes in client circumstances, changes in world or economic events, and changes to the models used to construct client portfolios, among others. IARs also review accounts continuously in light of changing market conditions. Changes in the tax code or tax rulings also trigger reviews for any impact on client portfolios and other tax consequences. Additionally, client portfolios are reviewed and rebalanced periodically to maintain the asset allocation designations for the account. For Charter Investment Advisory services, clients will receive quarterly portfolio reports from the custodian, LPL. LPL OMP Program: In addition to the quarterly portfolio reports described in the applicable program Wrap Brochure or the Form ADV Part 2A of LPL, LPL will transmit to clients: (1) trade confirmations unless the trade is the result of a systematic purchase, systematic redemption or systematic exchange; and (2) account statements, showing all transactions in cash and securities and all deposits and withdrawals of principal and income during the preceding calendar month. LPL Manager Access Select, Model Wealth Portfolios and Personal Wealth Portfolios Programs: In addition to the quarterly portfolio reports described in the applicable program Wrap Brochure or the Form ADV Part 2A of LPL, LPL will transmit to clients account statements showing all transactions in cash and securities and all deposits and withdrawals of principal and income during the preceding calendar month. The third party adviser will provide reports to the clients to include a statement at least quarterly. 21  Charter Advisory Corporation Form ADV Part 2A Brochure Client Referrals and Other Compensation CLIENT REFERRALS Our firm may pay referral fees to independent persons or firms ("Promoters") for introducing clients to us. Whenever we pay a referral fee, we require the Promoter to provide the prospective client with a copy of this document (our Firm Brochure) and a separate disclosure statement that includes the following information: the Promoter’s name and relationship with our firm; the fact that the Promoter is being paid a referral fee; the amount of the fee; and     whether the fee paid to us by the client will be increased above our normal fees in order to compensate the Promoter. As a matter of firm practice, the advisory fees paid to us by clients referred by Promoters are not increased as a result of any referral. Custody Charter’s Agreement and/or the separate agreement with a qualified custodian may authorize Charter, through the qualified custodian, to debit the client’s Account for the amount of Charter’s fee and to directly remit that management fee to Charter in accordance with applicable custody rules. The qualified custodian for client accounts, from which Charter retains the authority to directly deduct fees, have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Charter. Clients should receive at least quarterly statements from the broker/dealer, bank or other qualified custodian that holds and maintains client’s investment assets. Charter urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 22  Charter Advisory Corporation Form ADV Part 2A Brochure Investment Discretion For Charter Investment Advisory accounts, clients may grant Charter authorization to manage client’s account on a discretionary basis. Discretionary authorization provides Charter the ability to determine the securities to be purchased and sold and when such securities are purchased and sold. Client will grant such authority to Charter by execution of the client agreement. Where Charter enters into non-discretionary arrangements with clients, Charter will obtain client approval prior to the execution of any trade. Voting Client Securities Charter will not vote proxies on behalf of client accounts. Although, on rare occasions and only at the client’s request, Charter may offer clients advice regarding corporate actions and the exercise of proxy voting rights/material. Class Action Lawsuits From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Charter has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. It also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Charter has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where Charter receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials, to the client. Electronic mail is acceptable where appropriate, and the client has authorized contact in this manner. Financial Information Registered investment advisers are required to provide you with certain financial information or disclosures about Charter’s financial condition. Charter has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. Charter does not require prepayment of any advisory fees of $1,200 or more, 6 months or more in advance. 23 

Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Cover Page Charter Advisory Corporation 250 E. 96th Street, Suite 200, Indianapolis, IN 46240 (317) 844-7416 www.charteradvisory.com March 24, 2026 This Wrap Fee Program Brochure provides information about the qualifications and business practices of Charter Advisory Corporation. If you have any questions about the contents of this Brochure, please contact Michael J. Kelley at (317) 844-7416 or via email at mkelley@charteradvisory.com. 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. Charter Advisory Corporation is an SEC Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Charter Advisory Corporation is also available on the SEC’s website at www.adviserinfo.sec.gov. i  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Material Changes In the past we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to new SEC Rules, we will ensure that you receive a summary of any materials changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. Investment advisors must update the information in their firm brochure at least annually. In lieu of providing clients with an updated brochure each year, we will provide Charter Advisory Corporation’s existing advisory clients with this summary page describing any material changes since the last annual update of the brochure. We will deliver a brochure or summary each year to existing clients within 120 days of the close of Charter Advisory Corporation’s fiscal year. Clients wishing to receive a complete copy of the current brochure may request a brochure by contacting Michael J. Kelley at (317) 844-7416 or via email at mkelley@charteradvisory.com. We have no material changes from the prior brochure dated March 20, 2025. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Additional information about Charter Advisory Corporation is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Charter Advisory Corporation who are registered, or are required to be registered, as investment adviser representatives of Charter Advisory Corporation. ii  Charter Advisory Corporation Form ADV Part 2A, Appendix 1 Wrap Fee Program Brochure Table of Contents Cover Page ....................................................................................................................................... i Material Changes ............................................................................................................................ ii Table of Contents ........................................................................................................................... iii Services, Fees and Compensation .................................................................................................. 1 Performance-Based Fees and Side-By-Side Management ........................................................... 4 Account Requirements and Types of Clients ................................................................................. 4 Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 4 Client Information Provided to Portfolio Managers ..................................................................... 5 Client Contact with Portfolio Managers ........................................................................................ 5 Disciplinary Information ................................................................................................................ 5 Other Financial Industry Activities and Affiliations .................................................................... 6 Code of Ethics ................................................................................................................................. 7 Brokerage Practices ........................................................................................................................ 9 Review of Accounts ....................................................................................................................... 12 Client Referrals and Other Compensation .................................................................................. 12 Custody .......................................................................................................................................... 13 Investment Discretion ................................................................................................................... 13 Voting Client Securities ................................................................................................................ 13 Class Action Lawsuits ................................................................................................................... 14 Financial Information .................................................................................................................. 14 iii   Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Services, Fees and Compensation Charter Advisory Corporation (hereinafter "Charter" or the "Firm"), offers personalized investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Charter’s services and fee arrangements are described in the following pages. Charter is a corporation formed under the laws of the State of Indiana. Charter has been conducting advisory services since 1979. Michael J. Kelley is the principal owner and President of Charter Advisory Corporation. This narrative provides clients with information regarding Charter and the qualifications, business practices, and nature of advisory services that should be considered before becoming an advisory client of Charter. Individuals associated with Charter will provide its investment advisory services. These individuals are authorized to provide advisory services on behalf of Charter. Such individuals are known as Investment Adviser Representatives (IARs). IARs with Charter are registered representatives of LPL Financial, a licensed full service securities broker/dealer and investment adviser under federal and state securities laws, located in Boston, Massachusetts. LPL Financial is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investors Protection Corporation (“SIPC”). Securities transactions for LPL's brokerage clients are executed through LPL. Charter is not an affiliate of LPL Financial. Charter’s Investment Advisory Services Charter provides investment advisory services to its clients on a discretionary and non- discretionary basis. The advisory services include, among other things, providing advice regarding asset allocation and the selection of investments. Account management is guided by the stated objectives of the client. In addition, the Adviser considers the client’s risk profile and financial status prior to making any recommendations. Management fees are paid quarterly in advance. Fees are due on the first day of the billing quarter and may be billed directly to the client or deducted from the advisory account. Fees are based on the account’s asset value as of the last business day of the prior billing quarter and are prorated for accounts opened during the quarter. 1  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Fees are negotiable and will be reviewed with each client to discuss the scope prior to entering into an agreement. An advisory client will have a period of five (5) business days from the date of signing the investment management agreement to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, either party may terminate the agreement with 30 days written notice. The account custodian may charge fees, which are in addition to and separate from the investment advisory service fee. Custodians may charge accounts for various transaction costs, retirement plan and administration fees. In addition, some mutual fund assets deposited in the account may have been subject to deferred sales charges and 12b (1) fees and other mutual fund annual expenses as described in each fund’s prospectus. Advisory clients should also note that fees for comparable services vary and lower fees for comparable services may be available from other sources. Conflicts of Interest Charter receives compensation as a result of a client’s participation in an LPL program. Depending on, among other things, the type and size of the account, type of securities held in the account, changes in its value over time, the ability to negotiate fees or commissions, the historical or expected size or number of transactions, and the number and range of supplementary advisory and client- related services provided to the client, the amount of this compensation may be more or less than what the Advisor would receive if the client participated in other programs, whether through LPL or another sponsor, or paid separately for investment advice, brokerage and other services. The account fee may be higher than the fees charged by other investment advisers for similar services. Clients should consider the level and complexity of the advisory services to be provided when negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with Charter. Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of conflicts of interest for each LPL Financial sponsored advisory program. Strategic Wealth Management (SWM) Program In the SWM program, Charter provides ongoing investment advice and management of assets in a client’s account that is tailored to the individual needs of the client based on the investment objective chosen by the client. Charter is typically granted discretion to purchase and sell mutual funds, equities, exchange-traded funds (“ETFs”), closed end funds, fixed income securities, unit 2  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure investment trusts and options. In the SWM program, LPL is providing brokerage, custodial and administrative services to the account. LPL is not an investment adviser to the client and has no authority or responsibility for investment decisions made for the account. Under the consolidated SWM program, SWM clients pay transaction charges for the purchase and sale of certain securities in their SWM accounts, unless their advisor elects to pay transaction charges on their behalf. Clients should be aware that the advisor pays LPL transaction charges for those transactions. The transaction charges paid by the advisor vary based on the type of transaction (e.g., mutual fund, equity or ETF) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees, asset-based service fees and/or recordkeeping fees to LPL. The amount of these transaction charges is set forth in the SWM Account Agreement and the accompanying fee schedule (available here - https://www.lpl.com/disclosures.html). Being subject to transaction charges results in higher fees and expenses and, as a result, reduces investment returns. Because the advisor has elected to pay the transaction charges in SWM accounts on behalf of the Client, there is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50, or where transaction fees vary based on the type of transaction. Clients should understand that the cost to Advisor of transaction charges may be a factor that the advisor considers when deciding which securities to select and how frequently to place transactions in a SWM account. The advisor determines the account fee for each client within the SWM program, subject to a maximum account fee of 3.00%. SWM does not require a minimum account size. Fee Billing for LPL custodied advisory accounts For advisory accounts custodied at LPL, unless otherwise instructed by Charter, LPL will deduct Advisor’s fee quarterly in advance; however, for the initial fee deduction, LPL will deduct the Advisor’s fee at the beginning of the quarter following the establishment of the Account and will include a prorated fee for the initial quarter in addition to the quarterly Advisor fee for the upcoming quarter. Subsequent fee deductions will be made at the beginning of each quarter based on the value of the Account assets as of the close of business on the last business day of the preceding quarter. Additional deposits and withdrawals will be added or subtracted from the assets, which may lead to an adjustment of the Advisor’s fee. If LPL is notified by Charter or the client of the termination or deactivation of the Account’s advisory account status at LPL, LPL will process a prorated refund of Advisor’s fees that were prepaid based upon the number of days remaining in the quarter after the notice of termination to LPL. 3  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Charter manages assets on a discretionary or nondiscretionary basis. As of December 31, 2025, Charter managed $333,085,121 of client assets of which, $275,846,221 in 861 accounts are managed on a discretionary basis and $57,238,900 in 16 accounts are managed on a non- discretionary basis. Performance-Based Fees and Side-By-Side Management The fees charged are calculated in the previous Fee and Compensation section, and are not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client (15 U.S.C. §80b-5(a)(1 )). Account Requirements and Types of Clients Charter offers personalized investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Investments in the Charter Advisory Services Wrap Fee program do not require a minimum account size, however accounts will be reviewed by Charter on a periodic basis for suitability based on account size, allocations and frequency of trades. Charter reserves the right to discontinue or terminate advisory services for any account that is not deemed economical or suitable. Methods of Analysis, Investment Strategies and Risk of Loss Charter will evaluate securities based on a fundamental or technical analysis using charts or cyclical studies. Fundamental analysis is a method of evaluating a security that entails attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. The primary risk of fundamental analysis is that estimates of intrinsic value might be incorrect. Technical analysis is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. The primary risk of Technical analysis is that past market performance is not always an indicator of future market performance. 4  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Each client will meet with Charter to discuss the specific investment strategy to be used such as long-term purchases, short term purchases, trading (securities sold within 30 days), margin and option trades. Charter may advise its investment advisory clients on other partnership investments such as mining precious metals, agricultural business, cable TV, equipment leasing and/or venture capital. Securities and other types of investments all involve different types and levels of risk that the client should be prepared to bear. Frequent trading can effect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investment risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their accounts. Clients must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with clients, Charter attempts to identify the balance of risks and rewards that is appropriate and comfortable for the client. It is still the client’s responsibility to ask questions if he or she does not fully understand the risks associated with any investment. Clients are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. Charter cannot assure clients that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. Client Information Provided to Portfolio Managers In opening an advisory account, IARs obtain the necessary financial data from the client, assist the client in determining the suitability of the Charter program and assist the client in setting appropriate investment objectives. Client Contact with Portfolio Managers Clients may contact the IAR directly to discuss their accounts in detail. Disciplinary Information Investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Charter or the integrity of Charter’s management. 5  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Charter has no information applicable to this Item. Other Financial Industry Activities and Affiliations IARs of Charter are separately licensed as registered representatives of LPL Financial. In this capacity, associated persons are involved in the sale of securities of various types, including, but not limited to stocks, bonds, mutual funds, variable annuities, and limited partnerships. In addition, associated persons may also be involved in the sale of insurance products. As such, associated persons can effect transactions in insurance products for clients and earn commissions for these activities. All compensation received by IARs of Charter for securities transactions through LPL Financial will be separate, yet customary for effecting securities transactions, including 12b-1 fees for the sale of investment company products. IARs may make differing recommendations with respect to the same securities or insurance products to different advisory clients. All recommendations made are specific to each client’s individualized needs and current financial situation. IARs, in their function as registered representatives and/or insurance agents, will effect securities transactions through LPL Financial. If an advisory client implements recommendations made by the associated person by purchasing securities or other products through LPL Financial, the IAR of Charter, in their separate capacity as a registered representative of LPL Financial will receive additional compensation in the form of commissions, including 12b- 1 fees for the sale of investment company products. Certain IARs of Charter may be licensed as a CPA and/or an insurance agent and are affiliated with accounting firms and/or insurance agencies. Compensation may be received for these services, including fees for accounting services performed and commissions on insurance products provided. As part of their practice, financial recommendations may be made to clients of Charter by the CPA and/or insurance agent. Charter's clients are advised that they are under no obligation to act on these recommendations and have total freedom to implement recommendations through any investment advisor of their choosing. Charter's clients are advised that they have total freedom to implement recommendations through any broker/dealer of their choosing. 6  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure As part of their fiduciary duty, Charter, and its associated persons endeavor at all times to put the interest of the client first, clients should be aware that receipt of additional compensation itself creates a potential conflict of interest. Code of Ethics IARs of Charter may purchase the same securities or other products recommended to clients for their own account. At no time will such a transaction be of such a size to influence the market for the security. Records of any such transactions are available for review. Charter or individuals associated with Charter may buy or sell – for their personal account(s) investment products identical to those recommended to clients. As these situations may represent a conflict of interest, Charter has established a code of ethics, the full text of which is available upon request; and it includes the following restrictions in order to ensure Charter’s fiduciary responsibilities: • Charter emphasizes the unrestricted right of the client to specify investment objectives, guidelines, and/or conditions on the overall management of their account. • Associated persons or their immediate family members shall not buy or sell securities for their personal portfolio(s) where their decision is derived in whole or in part, because of the associated person’s employment, unless the information is also available to the investing public on reasonable inquiry. • No associated person of Charter shall prefer his or her own interest to that of the advisory client. Where suitable, investment opportunities must be offered first to clients before Charter or associated persons may participate in such transactions. • Charter requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. • Any individual not in observance of the above may be subject to termination. Charter also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by Charter or any associated person. Charter’s clients or prospective clients may request a copy of Charter’s Code of Ethics by contacting Michael J. Kelley at (317) 844-7416 or via email at mkelley@charteradvisory.com. 7  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure It is Charter’s policy that Charter will not affect any principal or agency cross securities transactions for client accounts. Charter will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker/dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker/dealer or has an affiliated broker/dealer. Privacy Policies Charter views protecting its clients’ private information as a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act, Charter has instituted policies and procedures to ensure that client information is kept private and secure. Charter does not disclose any nonpublic personal information about its clients or former clients to any nonaffiliated third parties, except as permitted by law. In the course of servicing a client’s account, Charter may share some information with its service providers, such as transfer agents, custodians, broker/dealers, accountants and lawyers. Charter restricts internal access to nonpublic personal information about the client to those employees who need to know that information in order to provide products or services to the client. As emphasized above, it has always been and will always be Charter’s policy never to sell information about current or former clients or their accounts to anyone. It is also Charter’s policy not to share information unless required to process a transaction, at the request of a client, or as required by law. Use of External Custodians As discussed previously, certain associated persons of Charter are registered representatives of LPL Financial. As a result of this relationship, LPL Financial may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about 8  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Charter’s clients in order to supervise certain activities of Charter’s Advisors, even if client does not establish any account through LPL. If you would like a copy of the LPL Financial privacy policy, please contact Charter at . Brokerage Practices Charter will recommend that a client in need of brokerage and custodial services utilize LPL Financial. Client may be able to obtain lower commissions and fees from other brokers. Investment adviser representatives of Charter are also associated with LPL Financial as broker- dealer registered representatives (“Dually Registered Persons”). In their capacity as registered representatives of LPL Financial, certain Dually Registered Persons may earn commissions for the sale of securities or investment products that they recommend for brokerage clients. They do not earn commissions on the sale of securities or investment products recommended or purchased in advisory accounts through Charter. Dually Registered Persons are restricted by certain FINRA rules and policies from maintaining client accounts at another custodian or executing client transactions in such client accounts through any broker-dealer or custodian that is not approved by LPL Financial. As a result, Charter reserves the right not to accept a client account if the client chooses to select a broker or dealer other than LPL Financial. Clients should also be aware that for accounts where LPL Financial serves as the custodian, Charter is limited to offering services and investment vehicles that are approved by LPL Financial, and may be prohibited from offering services and investment vehicles that may be available through other broker-dealers and custodians, some of which may be more suitable for a client’s portfolio than the services and investment vehicles offered through LPL Financial. Clients should understand that not all investment advisers require that clients custody their accounts and trade through specific broker-dealers. As stated previously, individuals associated with Charter are licensed as registered representatives of LPL Financial. As a result of this licensing relationship, LPL Financial is responsible for supervising certain activities of Charter to the extent Charter manages assets at a broker/dealer and 9  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure custodian other than LPL Financial. LPL Financial charges a fee of up to 10 basis points to Charter for this oversight. This presents a conflict of interest in that Charter has a financial incentive to recommend that you maintain your account with LPL Financial rather than another custodian in order to avoid the oversight fee. However, to the extent Charter recommends you use LPL Financial for such services, it is because Charter believes that it is in your best interest to do so based on the quality and pricing of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services provided by LPL Financial. Benefits of Using LPL as Custodian1 Charter receives support services and/or products from LPL Financial, many of which assist Charter to better monitor and service program accounts maintained at LPL Financial; however, some of the services and products benefit Charter and not client accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate. Such compensation provided to Charter includes other types of compensation, such as bonuses, awards or other things of value offered by LPL to Charter, and may include the following:  Payments based on production;  Equity awards from LPL’s parent company, LPL Financial Holdings Inc., consisting of awards of either restricted stock units or stock options to purchase stock, in each case subject to satisfaction of vesting and other conditions;  Reimbursement or credit of fees that [Advisor] pays to LPL for items such as administrative services or technology fees;  Free or reduced-cost marketing materials;  Payments in connection with the transition of association from another broker- dealer or investment advisor firm to LPL;  Payments in the form of repayable or forgivable loans;  Advances of advisory fees; and/or  Attendance at LPL conferences and events. LPL Financial may provide these services and products directly or may arrange for third party vendors to provide the services or products to Advisor. In the case of third party vendors, LPL Financial may pay for some or all of the third party’s fees. These support services are provided to Charter based on the overall relationship between Charter and LPL Financial. It is not the result of soft dollar arrangements or any other express 10  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure arrangements with LPL Financial that involves the execution of client transactions as a condition to the receipt of services. Charter will continue to receive the services regardless of the volume of client transactions executed with LPL Financial. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by Charter to LPL or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. However, because Charter receives these benefits from LPL Financial, there is a potential conflict of interest. The receipt of these products and services presents a financial incentive for Charter to recommend that its clients use LPL Financial’s custodial platform rather than another custodian’s platform. For a further listing of potential conflicts, please refer to LPL Financial’s Brokerage Compensation and Conflicts Disclosure, available at lpl.com/disclosures.html. Transition Assistance LPL also provides various benefits and/or payments to Advisors that are new to the LPL platform to assist them with the costs (including foregone revenues during account transition) associated with transitioning their business to LPL (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the Advisor’s business, satisfying any outstanding debt owed to the Advisor’s prior firm, offsetting account transfer fees (ACATs) as a result of the Advisor’s clients transitioning to LPL’s custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. The amount of the Transition Assistance payments is often significant in relation to the overall revenue earned or compensation received by the Advisor at their prior firm. Such payments are generally based on the size of the Advisor’s business established at the prior firm. These payments are generally in the form of payments or loans to the Advisor with favorable interest rate terms as compared to other lenders, which are paid by LPL or forgiven by LPL based on years of service with LPL (e.g., if the Advisor remains with LPL for 5 years) and/or the scope of business engaged in with LPL. LPL does not verify that any payments made are actually used for such transition costs. The receipt of Transition Assistance creates a conflict of interest in that Advisor has a financial incentive to recommend that a client open and maintain an account with Charter and LPL for advisory, brokerage and/or custody services, and to recommend switching investment products or services where a client’s current investment options are not available through LPL, in order to 11  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure receive the Transition Assistance benefit or payment, and in cases of businesses not supported by LPL, to further recommend that a client’s current holdings be reinvested in a program offering LPL does support. LPL and Charter Advisor’s attempt to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the Transition Assistance earned by any particular Advisor. However, clients should be aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with LPL. If LPL makes a loan to the Advisor, there is also a conflict of interest because LPL’s interest in collecting on the loan affects its ability to objectively supervise the registered representatives. Review of Accounts The IAR reviews the client’s portfolio periodically by reviewing all security positions held by clients under the IAR’s supervision. Triggering factors of additional reviews may include changes in client circumstances, changes in world or economic events, and changes to the models used to construct client portfolios, among others. IARs also review accounts continuously in light of changing market conditions. Changes in the tax code or tax rulings also trigger reviews for any impact on client portfolios and other tax consequences. Additionally, client portfolios are reviewed and rebalanced periodically to maintain the asset allocation designations for the account. For Charter Investment Advisory services, clients will receive quarterly portfolio reports from the custodian, LPL. Client Referrals and Other Compensation CLIENT REFERRALS Our firm may pay referral fees to independent persons or firms ("Promoters") for introducing clients to us. Whenever we pay a referral fee, we require the Promoter to provide the prospective client with a copy of this document (our Firm Brochure) and a separate disclosure statement that includes the following information: the Promoter’s name and relationship with our firm; the fact that the Promoter is being paid a referral fee; the amount of the fee; and     whether the fee paid to us by the client will be increased above our normal fees in order to 12  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure compensate the Promoter. As a matter of firm practice, the advisory fees paid to us by clients referred by Promoters are not increased as a result of any referral. Custody Charter’s Agreement and/or the separate agreement with a qualified custodian may authorize Charter, through the qualified custodian, to debit the client’s Account for the amount of Charter’s fee and to directly remit that management fee to Charter in accordance with applicable custody rules. The qualified custodian for client accounts, from which Charter retains the authority to directly deduct fees, have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Charter. Clients should receive at least quarterly statements from the broker/dealer, bank or other qualified custodian that holds and maintains client’s investment assets. Charter urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Investment Discretion For Charter Investment Advisory accounts, clients may grant Charter authorization to manage client’s account on a discretionary basis. Discretionary authorization provides Charter the ability to determine the securities to be purchased and sold and when such securities are purchased and sold. Client will grant such authority to Charter by execution of the client agreement. Where Charter enters into non-discretionary arrangements with clients, Charter will obtain client approval prior to the execution of any trade. Voting Client Securities Charter will not vote proxies on behalf of client accounts. Although, on rare occasions and only at the client’s request, Charter may offer clients advice regarding corporate actions and the exercise of proxy voting rights/material. 13  Charter Advisory Corporation Form ADV 2A, Appendix 1 Wrap Fee Program Brochure Class Action Lawsuits From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. Charter has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. It also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Charter has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where Charter receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials, to the client. Electronic mail is acceptable where appropriate, and the client has authorized contact in this manner. Financial Information Registered investment advisers are required to provide you with certain financial information or disclosures about Charter’s financial condition. Charter has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. 14