Cornell Pochily Investment Advisors, Inc.

Disclosure Brochure Disclosure Brochure March 30, 2026 2415 North Triphammer Road, Suite 1 Ithaca, NY 14850 (607) 391-7080 www.cornellpochily.com This brochure provides information about the qualifications and business practices of Cornell Pochily Investment Advisors, Inc. (hereinafter “Cornell Pochily” or the “Firm”). If you have any questions about the contents of this brochure, please contact Cornell Pochily at (607) 391-7080. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Cornell Pochily is available on the SEC’s website at www.adviserinfo.sec.gov. Cornell Pochily is an SEC registered investment adviser. Registration does not imply any level of skill or training. © MarketCounsel 2026  Disclosure Brochure Item 2. Material Changes In this Item, the Firm is required to discuss any material changes that have been made to the brochure since the last annual amendment dated March 28, 2025. The Firm has no material changes to disclose. © MarketCounsel 2026 Page ii  Disclosure Brochure Item 3. Table of Contents Item 1. Cover Page ....................................................................................................................................... i Item 2. Material Changes ............................................................................................................................. ii Item 3. Table of Contents ............................................................................................................................. iii Item 4. Advisory Business ............................................................................................................................ 4 Item 5. Fees and Compensation .................................................................................................................. 6 Item 6. Performance-Based Fees and Side-by-Side Management ............................................................. 9 Item 7. Types of Clients ............................................................................................................................. 10 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 11 Item 9. Disciplinary Information .................................................................................................................. 17 Item 10. Other Financial Industry Activities and Affiliations ....................................................................... 18 Item 11. Code of Ethics .............................................................................................................................. 19 Item 12. Brokerage Practices ..................................................................................................................... 20 Item 13. Review of Accounts...................................................................................................................... 23 Item 14. Client Referrals and Other Compensation ................................................................................... 24 Item 15. Custody ........................................................................................................................................ 25 Item 16. Investment Discretion................................................................................................................... 26 Item 17. Voting Client Securities ................................................................................................................ 27 Item 18. Financial Information .................................................................................................................... 28 © MarketCounsel 2026 Page iii  Disclosure Brochure Item 4. Advisory Business Cornell Pochily is a registered investment advisory firm founded by principals Ezra Cornell and Robert Pochily in January 2008 to more efficiently address the investment needs of their clients. The Firm is principally owned by Ezra Cornell, Nelson B. Mead, Shane P. O’Neill, and Molly O’Neill. Cornell Pochily provides investment services, financial planning, consulting, and tax preparation services. Prior to engaging Cornell Pochily to provide any of the foregoing services, the client is required to enter into one or more written agreements with Cornell Pochily setting forth the terms and conditions under which Cornell Pochily renders its services (collectively the “Agreement”). As of December 31, 2025, Cornell Pochily had $654,434,441 in regulatory assets under management, all of which were managed on a discretionary basis. Cornell Pochily had an additional $183,760,672 in which the Firm considered “assets under advisement,” for which it provided more limited non-discretionary services. This disclosure brochure describes the business of Cornell Pochily. Certain sections will also describe the activities of the Firm and its personnel who are all subject to Cornell Pochily’s supervision or control. Investment Services Cornell Pochily provides investment services for clients on all or a portion of their assets on a discretionary or non-discretionary basis. When managing on a discretionary basis, Cornell Pochily primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), and/or individual debt and equity securities in accordance with the investment objectives and risk tolerance of the client. While the Firm generally does not invest client assets in initial public offerings (“IPOs”) of equity, it may invest in such offerings upon a client’s request. The Firm may also provide advice about any type of investment held in clients' portfolios as required based on a client’s needs. Clients may choose to hold positions that are excluded from management or are not continuously monitored or otherwise advised upon by the Firm. Cornell Pochily is given non-discretionary authority for consulting services to some clients who desire to maintain full discretion over their accounts and who choose to initiate discussions with the Firm to handle trades in their accounts. Cornell Pochily tailors its investment advisory services to the individual needs of clients. Cornell Pochily consults with clients initially and on an ongoing basis to determine the client’s needs, objectives, risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Cornell Pochily strives to ensure that clients’ investments are appropriate for their investment needs, objectives and risk © MarketCounsel 2026 Page 4  Disclosure Brochure tolerance, and for any other factors that may have been identified and are also appropriate for the client’s time horizon. Clients are advised to promptly notify Cornell Pochily if there are changes in their life circumstances, need for liquidity, financial situation and/or investment objectives or if they wish to impose any reasonable restrictions upon Cornell Pochily’s investment services. Financial Planning and Consulting Services Cornell Pochily provides clients with a broad range of comprehensive financial planning and consulting services (which can include non-investment related matters). These services generally include investment and asset allocation planning, retirement planning, personal budget planning, long-term financial planning, basic estate planning and tax preparation. In addition, Cornell Pochily provides consulting services to individual participants in self-directed pension and profit sharing plans. Cornell Pochily will also render consulting services relative to variable life/annuity products that the client(s) own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that are not held by the client’s primary custodian. In so doing, Cornell Pochily either directs or recommends the allocation of client assets among various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. When the Firm agrees to provide financial planning services for a client(s), the scope of the engagement, and any limitations, the period during which the services will be provided and the client’s responsibilities will be reviewed and set forth in the Agreement. Unless specifically included in the Agreement, implementing, monitoring and updating the financial planning recommendations are excluded from the scope of the engagement. In performing its services, Cornell Pochily is not required to verify any information received from the client or from the client’s other professionals (i.e., attorney, accountant, etc.) and is expressly authorized to rely on such information. Cornell Pochily can recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Cornell Pochily recommends its own services. The client is under no obligation to act upon any of the recommendations made by Cornell Pochily under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Cornell Pochily itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Cornell Pochily’s recommendations. Clients are advised that it remains their responsibility to promptly notify Cornell Pochily if there is ever any change in their life circumstances, need for liquidity, financial situation and/or investment objectives for the purpose of reviewing, evaluating, or revising Cornell Pochily’s previous recommendations and/or services. © MarketCounsel 2026 Page 5  Disclosure Brochure Item 5. Fees and Compensation Cornell Pochily offers its services based upon assets under management, as well as on a set fee basis, which includes hourly and/or fixed fees. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Cornell Pochily for additional services for compensation, including its tax preparation services, rolling over retirement accounts, or moving other assets to the Firm’s management. Clients retain the absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Investment Services Fee Cornell Pochily provides investment management services under discretion for an annual fee based upon a percentage of the market value of the assets being managed for the client by Cornell Pochily. Cornell Pochily’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the client. Cornell Pochily does not, however, receive any portion of these commissions, fees, and costs. Cornell Pochily’s annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by Cornell Pochily on the last day of the previous quarter. The annual fee varies (up to 1.25%) depending upon the market value of the assets under management and the type of investment management services to be rendered. Under some circumstances the Firm has charged a fixed fee for investment management. Cornell Pochily, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (e.g., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.). The Firm includes cash in a client’s account in determining the valuation for billing purposes. For those clients who are provided investment services on a non-discretionary basis, Cornell Pochily will negotiate a fee depending on the level of service needed from the Firm by the client. These fees generally range from $100 to $10,000 on a fixed fee basis and/or from $150 to $350 on an hourly rate basis, depending upon the level and scope of the investment services. Financial Planning and Consulting Fees Cornell Pochily will charge a fixed fee and/or hourly fee for financial planning and consulting services. These fees are negotiable, but generally range from $100 to $10,000 on a fixed fee basis and/or from © MarketCounsel 2026 Page 6  Disclosure Brochure $150 to $350 on an hourly rate basis, depending upon the level and scope of the financial planning and/or consulting services. If the client engages Cornell Pochily for additional investment services, Cornell Pochily may offset all or a portion of its fees charged for the financial planning and/or consulting services. For tax preparation, these fees are negotiable, but generally range from $75 to $2,500 on a fixed fee basis, depending upon the level and scope of the services. These services will be provided under a separate engagement. Where Cornell Pochily is providing consulting services to individual participants in self-directed pension and profit sharing plans, or other clients that do not need the regular supervision provided in an investment management relationship, Cornell Pochily charges $100 to $10,000 on a fixed fee basis and/or $150 to $350 on an hourly rate basis or an asset-based fee of up to 1.25% based upon the market value of the assets in the individual account on the last day of the previous quarter. The annual fee is prorated and charged quarterly, in advance. Prior to engaging Cornell Pochily to provide financial planning and/or consulting services, the client is required to enter into a written agreement with Cornell Pochily setting forth the terms and conditions of the engagement. Cornell Pochily may require up to one-half of the financial planning/consulting fee for fixed fee or hourly fee engagements payable upon entering the written agreement. The Firm does not, however, take receipt of $1,200 or more in prepaid fees, six months in advance of services rendered. The balance is generally due upon delivery of the financial plan or completion of the agreed upon services. Fees Charged by Financial Institutions As further discussed in response to Item 12 (below), Cornell Pochily generally recommends that clients utilize the brokerage and clearing services of National Financial Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, “Fidelity”) for their accounts. Cornell Pochily may only implement its investment management recommendations after the client has arranged for and furnished Cornell Pochily with required information and authorization regarding accounts with appropriate financial institutions. Financial institutions include, but are not limited to, Fidelity, any other broker-dealer recommended by Cornell Pochily, broker-dealer directed by the client, trust companies, banks, etc. (collectively referred to herein as the “Financial Institutions”). Clients incur certain charges imposed by the Financial Institutions and other third parties such as custodial fees, charges imposed directly by a mutual fund or exchange-traded products (“ETPs”) in the account, which are disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally, for assets outside of any wrap fee programs, clients will incur brokerage commissions and transaction fees. Any charges, fees and commissions imposed by the Financial Institution are exclusive of and in addition © MarketCounsel 2026 Page 7  Disclosure Brochure to Cornell Pochily’s fee. As noted above, Cornell Pochily does not receive any portion of the fees that are imposed by the Financial Institution. Cornell Pochily’s Agreement and the separate agreement with any Financial Institutions authorize Cornell Pochily to debit the client’s account for the amount of Cornell Pochily’s fee and to directly remit that fee to Cornell Pochily. Any Financial Institutions recommended by Cornell Pochily 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 Cornell Pochily. Alternatively, clients may elect to have Cornell Pochily send an invoice for payment. Fees for Services During Partial Quarters of Service For the initial period of investment services, the fees are calculated on a pro rata basis. The Agreement between Cornell Pochily and the client shall renew automatically unless terminated by either party pursuant to the terms of the Agreement. Consistent with the Agreement, Cornell Pochily’s fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. Clients may make additions to and withdrawals from their account at any time, subject to Cornell Pochily’s right to terminate a relationship with a client. Clients may withdraw account assets on notice to Cornell Pochily, subject to the usual and customary securities settlement procedures. However, Cornell Pochily designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. If assets are deposited into or withdrawn from an account after the inception of a quarter, the fee payable with respect to such assets will not be adjusted or prorated based on the number of days remaining in the quarter. Additions may be in cash or securities provided that Cornell Pochily reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Cornell Pochily may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. © MarketCounsel 2026 Page 8  Disclosure Brochure Item 6. Performance-Based Fees and Side-by-Side Management Cornell Pochily does not provide any services for performance-based fees. Performance-based fees are those based on a share of capital gains on or capital appreciation of the assets of a client. © MarketCounsel 2026 Page 9  Disclosure Brochure Item 7. Types of Clients Cornell Pochily provides its services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and business entities. © MarketCounsel 2026 Page 10  Disclosure Brochure Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Cornell Pochily makes use of the following methods of analysis: Fundamental analysis involves the fundamental financial condition and competitive position of a company. Cornell Pochily will use research that analyzes the financial condition, capabilities of management, earnings, new products and services, as well as the company’s markets and position amongst its competitors. The primary risk in using fundamental analysis is that while the overall health and position of a company may be good, market conditions may negatively impact the security. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Cornell Pochily will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the particular company that Cornell Pochily is recommending. The risks with cyclical analysis are similar to those of technical analysis. Also see Item 4, above for further description of our business. Investment Services For clients who utilize investment services and have their accounts managed under advisor discretion, Cornell Pochily constructs and manages customized portfolios based on client needs, objectives, risk tolerance, time horizon and other factors. In some cases, Cornell Pochily will use input from clients to develop the appropriate diversification and asset allocation for the individual client’s portfolio. In implementing portfolios, Cornell Pochily primarily utilizes individual equities, mutual funds, ETFs, government, municipal and corporate fixed income securities (including CDs, money market funds, and bonds of various maturities). Cornell Pochily may also incorporate exchange-traded notes and master limited partnerships in client portfolios, as appropriate. Cornell Pochily regularly monitors and adjusts client portfolios as conditions (both client-related and market) dictate. In selecting securities, Cornell Pochily uses both proprietary and external research. Cornell Pochily holds regular investment committee meetings and focuses on long term investing over generating returns through short term trading. As needed, Cornell Pochily may sell a security regardless of the holding period if there is some fundamental change in the company or if market or economic conditions warrant. © MarketCounsel 2026 Page 11  Disclosure Brochure In selecting mutual funds and ETPs (including ETFs), Cornell Pochily reviews, among other factors, cost, manager tenure, consistency of returns, risk, performance and underlying assets. For bond funds, Cornell Pochily also considers yield, credit quality, and duration. For certain individual clients managing their own portfolio, Cornell Pochily is given non-discretionary authority for consulting services to offer guidance regarding potential investment decisions. Such services may include: • Portfolio analysis: review of asset allocation, concentrated positions and cash flow; • Investment recommendations can include: fund, or individual security changes; and • Investment strategy: develop an investment focus such as, income, growth, and tax free income. Financial Planning Cornell Pochily’s financial plans are tailored to each individual, utilizing both technology and the training and experience of its advisors. See the Financial Planning and Consulting Services section in Item 4, above. While each financial plan is tailored to the client, the financial planning process generally follows a seven step process: • Understanding the client’s personal and financial circumstances; • Identifying and selecting goals; • Analyzing the client’s current course of action and potential alternative course(s) of action; • Developing the financial planning recommendation(s); • Presenting the financial planning recommendation(s); • Implementing the financial planning recommendation(s) (unless specifically excluded from scope of engagement); and • Monitoring progress and updating (unless specifically excluded from scope of engagement). Consulting Cornell Pochily provides consulting services for individual clients, companies, and retirement plans. For example, for individuals, Cornell Pochily will provide consulting services including, but not limited to the following: • Review of retirement plan: develop estimate of retirement cash flows and expected investment values; and • Estate plan review: recommend actions to consider to develop an estate plan. © MarketCounsel 2026 Page 12  Disclosure Brochure Specifically for companies and retirement plans, Cornell Pochily offers: • Existing retirement plan evaluation: review fund performance and participation rates; • Retirement plan selection: pooled, individual participant accounts, features and options; • Investment selection analysis: review available mutual fund offering and make recommendations; • Investment policy statement: develop an investment policy statement for client to consider; and • Participant education: conduct participant enrollment meetings and provide periodic presentations. Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm’s investment services. Clients should consult with their legal, tax, and other advisors before engaging the Firm to provide investment services on their behalf. Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. No one can predict the future and there is always a risk of loss, along with the hope of gain. The profitability of a significant portion of Cornell Pochily’s recommendations and/or investment decisions may depend to a great extent upon effective analysis, and the training and experience of our advisors to best try to anticipate and navigate the course of, among other factors, price movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial markets and economic conditions throughout the world. There can be no assurance that any investment will be successful. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm may temporarily invest some of a client’s assets in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its performance objective. The Firm charges investment fees based on all assets in an account, including money market and similar types of investments. © MarketCounsel 2026 Page 13  Disclosure Brochure Equity-Related Securities and Instruments The Firm may take positions in common stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to broad market risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small-capitalization, mid-capitalization and financially distressed companies may be subject to more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face greater business risks. Fixed Income Securities There are certain risks when investing in Fixed Income Securities. Fixed Income Securities are subject to price volatility due to many factors, including, but not limited to, changes in interest rates, changes in the issuer’s credit rating and changes in the direction of the economy, including inflation and deflation, changes in the value of the U.S. dollar and other economic stress. Mutual Funds and ETFs An investment in a mutual fund or ETF, the most common category of ETP, involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (i.e., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day when the market is open, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. © MarketCounsel 2026 Page 14  Disclosure Brochure There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Exchange-Traded Notes (“ETNs”) Cornell Pochily may recommend an investment in, or allocate assets among, various ETNs. ETNs are unsecured debt securities which are listed on securities exchanges and transacted at negotiated prices in the secondary market. ETNs are designed to track the performance of a corresponding benchmark. An ETN is essentially a contract between an issuer and the ETN holder, whereby the issuer, upon maturity, agrees to pay an amount relative to the returns of the underlying benchmark. In addition to the risks associated with the specific benchmark, ETN holders are also subject to various counterparty concerns. In this respect, the value of an ETN may be adversely impacted by a downgrade to the issuer’s credit rating and/or an unwillingness or inability of the issuer to perform its contractual obligations. Other ETPs There are other ETP structures that are very similar to ETFs that may not be registered under the Investment Company Act of 1940 and are classified as grantor trusts for tax purposes. These ETPS are used most commonly for investments in physical commodities, foreign currencies, and cryptocurrencies. ETPs share the same risks as ETFs (mentioned above), in addition to the risks associated with the underlying assets or futures contracts that the ETP invests in, including complete loss of value. Master Limited Partnerships (“MLPs”) MLPs are typically limited partnerships that are publicly traded on a U.S. securities exchange and are usually found in natural resources, real estate or financials. MLPs are subject to both market risk and risks specific to the issues (i.e., depleting oil wells). Depending on the type of account a MLP is held in, there may be temporary tax advantages, but investors may have to pay ordinary income tax on subsequent distributions if the MLP was held in a tax-deferred account. Initial Public Offerings Although Cornell Pochily generally does not invest client assets in equity IPOs, it may invest in such IPOs upon a client’s request. An IPO is the first sale of stock by a company to the public. It can be used by either small or large companies to raise expansion capital and become publicly traded enterprises. An investment in an IPO involves risk, including the loss of principal. IPOs are also subject to the risk that the per share value may fall in the days and weeks following the IPO, as well as underwriting risk, adverse market conditions and negative investor sentiment. © MarketCounsel 2026 Page 15  Disclosure Brochure Use of Margin Margin is subject to the approval of a broker-dealer or custodian. To the extent that a client authorizes the use of margin, and margin is thereafter employed by Cornell Pochily in the management of the client’s investment portfolio, the market value of the client’s account and corresponding fee payable by the client to Cornell Pochily will not be increased. While the use of margin borrowing can substantially improve returns, such use may also increase the adverse impact to which a client’s portfolio may be subject. Margin borrowings are based on an arrangement with a broker-dealer or custodian, and will typically be secured by the client's securities. When a client has a margin balance, the client is essentially borrowing money from the broker-dealer. The client is responsible to the broker-dealer for interest and fees that are incurred. Cornell Pochily does not benefit from the interest or fees charged by the broker-dealer. Under certain circumstances, such a broker-dealer may demand an increase in the collateral that secures the client’s obligations and if the client was unable to provide additional collateral, the broker-dealer could liquidate assets held in the account to satisfy the client’s obligations to the broker-dealer. Liquidation in that manner could have extremely adverse consequences. In addition, the amount of the client’s borrowings and the interest rates on those borrowings, which will fluctuate, will have a significant effect on the client’s profitability. Clients should understand the risk of loss before using margin debt. A broker- dealer or custodian will have risk disclosure information available. Non-U.S. Investments An advisory account that holds non-U.S. investments has risks that are specific to that country’s risks. Such risk of loss includes, but is not limited to, the financial risks of the economy and local markets, currency risk, geo-political risk, regulatory risk and risk involving accounting and financial standards. Cross Transactions In very limited circumstances, Cornell Pochily may engage in cross transactions pursuant to which Cornell Pochily may effect transactions between a client’s account and the accounts of other individuals and/or entities which may include clients of Cornell Pochily (e.g. arranging for the client’s securities trades by “crossing” these trades with securities transactions of other advisory and non-advisory clients). Cornell Pochily does not receive any special compensation (transaction-based or otherwise) for cross transactions. Cornell Pochily will only engage in cross transactions when it believes that such transactions are in the best interests of all clients involved. The client may revoke Cornell Pochily’s cross transaction authority at any time upon written notice to Cornell Pochily. The client’s custodian will set the cross level price. © MarketCounsel 2026 Page 16  Disclosure Brochure Item 9. Disciplinary Information Cornell Pochily is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of management. Cornell Pochily does not have any required disclosures to this Item. © MarketCounsel 2026 Page 17  Disclosure Brochure Item 10. Other Financial Industry Activities and Affiliations Cornell Pochily is required to disclose any relationship or arrangement that is material to its advisory business or to its clients with certain related persons. Cornell Pochily does not have any relationships or arrangements to describe. © MarketCounsel 2026 Page 18  Disclosure Brochure Item 11. Code of Ethics Cornell Pochily has adopted a code of ethics that sets forth the standards of conduct expected of its Personnel and requires compliance with applicable securities laws (“Code of Ethics”). In accordance with Section 204A of the Advisers Act, its Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public information by Cornell Pochily or by any persons associated with Cornell Pochily (“Personnel”). The Code of Ethics also requires that Cornell Pochily’s Personnel report their personal securities holdings and transactions and obtain pre-approval of certain investments such as IPOs and limited offerings. Personnel includes Associated Persons and Access Persons, as that term is defined under the Code of Ethics. Cornell Pochily and its Personnel are permitted to buy or sell securities that it also recommends to clients consistent with Cornell Pochily’s policies and procedures. Cornell Pochily’s Code of Ethics directs how the Firm’s Personnel may effect transactions for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household as the Personnel) of any security which is being actively purchased or sold, or is being considered for purchase or sale, on behalf of any of Cornell Pochily’s clients. Personnel or their immediate family may not effect any transaction in their own account for the same security as a client prior to the completion of the transaction for the client or until a decision not to buy or sell has been made for the client regarding such security. If the particular securities are not being traded for a client account then the Personnel are permitted to trade those securities in their own account(s), either upon preclearance from other Personnel and/or when possible, entered to execute at market close. Unless the Firm is actively considering buying or selling a security and executing the transaction over the course of more than one day then Personnel may trade such a security. Personnel may trade at the same time as clients through a “batch” trade with those clients provided that no other trades in that security are being considered for other clients (See Item 12 for a discussion of “batch” trades). These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients may contact Cornell Pochily to request a copy of its Code of Ethics. © MarketCounsel 2026 Page 19  Disclosure Brochure Item 12. Brokerage Practices As discussed above, in Item 5, Cornell Pochily generally recommends that clients utilize the brokerage, custody and clearing services of Fidelity. Factors which Cornell Pochily considers in recommending Fidelity, or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Fidelity enables Cornell Pochily to obtain for its clients many mutual funds without transaction charges and other securities with nominal transaction charges. The commissions and/or transaction fees charged by Fidelity may be higher or lower than those charged by other Financial Institutions. The commissions paid by Cornell Pochily’s clients comply with Cornell Pochily’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where Cornell Pochily determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Cornell Pochily seeks competitive rates, but may not necessarily obtain the lowest possible commission rates for client transactions. Transactions may be cleared through other Financial Institutions with whom Cornell Pochily and the Financial Institutions have entered into agreements for prime brokerage clearing services. Cornell Pochily periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. The client may direct Cornell Pochily in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution, and Cornell Pochily will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by Cornell Pochily (as described below). As a result, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, Cornell Pochily may decline a client’s request for a directed brokerage arrangement if, in Cornell Pochily’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties or violate restrictions imposed by other broker-dealers (as further discussed below). Transactions for each client will generally be affected independently, unless Cornell Pochily decides to purchase or sell the same securities for several clients at approximately the same time. Cornell Pochily may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among Cornell Pochily’s clients differences in prices © MarketCounsel 2026 Page 20  Disclosure Brochure and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will generally be averaged as to price and allocated among Cornell Pochily’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that Cornell Pochily determines to aggregate client orders for the purchase or sale of securities, including securities in which Cornell Pochily’s Supervised Persons may invest, Cornell Pochily generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Cornell Pochily does not receive any additional compensation or remuneration as a result of the aggregation. In the event that Cornell Pochily determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, Cornell Pochily may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Consistent with obtaining best execution, brokerage transactions may be directed to certain broker- dealers in return for investment research products and/or services which assist Cornell Pochily in its investment decision-making process. Such research generally will be used to service all of Cornell Pochily’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because Cornell Pochily does not have to produce or pay for the products or services. Software and Support Provided by Financial Institutions Cornell Pochily receives from Fidelity, without cost to Cornell Pochily, computer software and related systems support, which allow Cornell Pochily to better monitor client accounts maintained at Fidelity. Cornell Pochily receives the software and related support without cost because Cornell Pochily renders investment management services to clients who maintain assets at Fidelity. The software and related systems support may benefit Cornell Pochily, but not its clients directly. In fulfilling its duties to its clients, Cornell Pochily endeavors at all times to put the interests of its clients first. Clients should be aware, © MarketCounsel 2026 Page 21  Disclosure Brochure however, that Cornell Pochily’s receipt of economic benefits from a broker-dealer creates a conflict of interest since these benefits may influence Cornell Pochily’s choice of one institution over another broker- dealer that does not furnish compatible software, systems support, or services. Additionally, Cornell Pochily receives the following benefits from Fidelity: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its clients; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network for client order entry and account information. © MarketCounsel 2026 Page 22  Disclosure Brochure Item 13. Review of Accounts For those clients to whom Cornell Pochily provides investment services, on a discretionary basis, Cornell Pochily monitors and reviews those portfolios as part of an ongoing process. For those clients to whom Cornell Pochily provides investment services on a non-discretionary basis, reviews are conducted on an “as needed” basis. Reviews are conducted by one of Cornell Pochily’s financial advisors. All investment advisory clients are encouraged to discuss their needs, objectives, risk tolerance, time horizon, and other factors with Cornell Pochily and to keep Cornell Pochily informed of any changes thereto. It is valuable to all parties to discuss the impact resulting from any changes in the client's financial situation and/or objectives. Unless otherwise agreed upon, clients are directly provided with transaction confirmation notices and regular summary account statements from the broker-dealer or custodian for their account(s). © MarketCounsel 2026 Page 23  Disclosure Brochure Item 14. Client Referrals and Other Compensation Client Referrals The Firm does not currently provide compensation to any third-party solicitors for client referrals. Other Economic Benefits Cornell Pochily receives economic benefits from non-clients for providing advice or other advisory services to clients. This type of relationship poses a conflict of interest and any such relationship is disclosed in response to Item 12, above. © MarketCounsel 2026 Page 24  Disclosure Brochure Item 15. Custody Cornell Pochily’s Agreement and/or the separate agreement with any Financial Institution authorizes Cornell Pochily through such Financial Institution to debit the client’s account for the amount of Cornell Pochily’s fee and to directly remit that fee to Cornell Pochily in accordance with applicable custody rules. The Financial Institutions recommended by Cornell Pochily have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of fees paid directly to Cornell Pochily. Clients should carefully review the statements sent directly by the Financial Institutions. Cornell Pochily is also deemed to have custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. © MarketCounsel 2026 Page 25  Disclosure Brochure Item 16. Investment Discretion Cornell Pochily is given the authority to exercise discretion on behalf of clients. Cornell Pochily is considered to exercise investment discretion over a client’s account if it can effect transactions for the client without first having to seek the client’s consent. Cornell Pochily is given this authority through a power-of-attorney included in the Investment Management Agreement between Cornell Pochily and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). Cornell Pochily takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Financial Institutions to be utilized. © MarketCounsel 2026 Page 26  Disclosure Brochure Item 17. Voting Client Securities Cornell Pochily does not accept the authority to vote a client’s securities (e.g., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. © MarketCounsel 2026 Page 27  Disclosure Brochure Item 18. Financial Information Cornell Pochily does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In addition, Cornell Pochily is required to disclose any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. The Firm has not been the subject of a bankruptcy petition at any time. Cornell Pochily has no disclosures pursuant to this Item. © MarketCounsel 2026 Page 28  Disclosure Brochure Prepared by: © MarketCounsel 2026 Page 29