CORNERSTONE ADVISORS

ITEM 1 – COVER PAGE PART 2A OF FORM ADV: FIRM BROCHURE CORNERSTONE ADVISORS, LLC 6540 SW 10th Avenue Topeka, Kansas, 66615 (785) 273-2685 or (800) 235-9063 www.cstonegroup.com March 24, 2026 This brochure provides information about the qualifications and business practices of Cornerstone Advisors, LLC (“Cornerstone Advisors”). If you have any questions about the contents of this brochure, please contact Mark Bucholtz at 785-273-2685 or mbucholtz@cstonegroup.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. Cornerstone Advisors is a Registered Investment Advisor. Registration as an Investment Advisor with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about Cornerstone Advisors is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifier, known as an IARD number. The IARD number for Cornerstone Advisors is 114510. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 1  ITEM 2 – MATERIAL CHANGES This section of the Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) www.adviserinfo.sec.gov. There have been no material changes since our last annual amendment filing on March 25, 2025. If you would like another copy of this Brochure, please download it from the SEC Website as indicated above or you may contact our Chief Compliance Officer, Mark Bucholtz at 785-273-2685 or mbucholtz@cstonegroup.com. We encourage you to read this document in its entirety. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 2  ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE 1 ITEM 2 – MATERIAL CHANGES 2 ITEM 3 – TABLE OF CONTENTS 3 ITEM 4 – ADVISORY BUSINESS 4 ITEM 5 - FEES AND COMPENSATION 7 ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT 9 ITEM 7 - TYPES OF CLIENTS 9 ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 9 ITEM 9 - DISCIPLINARY INFORMATION 14 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 14 ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL 14 TRADING ITEM 12 - BROKERAGE PRACTICES 15 ITEM 13 - REVIEW OF ACCOUNTS 20 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION 20 ITEM 15 – CUSTODY 20 ITEM 16 – INVESTMENT DISCRETION 21 ITEM 17 – VOTING YOUR SECURITIES 21 ITEM 18 – FINANCIAL INFORMATION 22 Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 3  ITEM 4 – ADVISORY BUSINESS This Disclosure document is being offered to you by Cornerstone Advisors, LLC (“Cornerstone Advisors” or “Firm”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. We are an SEC registered investment management firm located in Topeka, Kansas. We specialize in investment advisory services for individuals, high net worth individuals, corporations, charitable organizations, trusts and estates. Cornerstone Advisors was established in 2000 as a registered investment advisor. The owners are Mark Bucholtz and Jeff Sorensen. We are committed to helping clients build, manage, and preserve their wealth, and to provide assistance that helps clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and Cornerstone Advisors execute an Investment Management Agreement. INVESTMENT MANAGEMENT SERVICES We manage advisory accounts on a discretionary or non-discretionary basis. Once we have determined a profile and investment plan with a client, we will execute the day-to-day transactions without seeking prior client consent. For those clients who have given us discretionary authority, besides day-to-day transactions, we will also execute trades without seeking prior client consent. Account supervision is guided by the profile and investment plan of the client. With our non- discretionary relationship, we will provide recommendations to help meet your financial objectives, but we must obtain your approval before making any transactions in your account. We may accept accounts with certain restrictions if circumstances warrant. We primarily allocate client assets among cash and cash equivalents, stocks, bonds, various mutual funds and Exchanged Traded Funds (“ETFs”) in accordance with their stated investment objectives. As appropriate, we may recommend non-traded REITS, structured notes, or other alternative investments for some qualified clients. We may also accommodate client requests for purchase of specific equities. All of which are considered asset allocation categories for the client’s investment strategy. During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance and liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family composition and background. Based on client needs, we develop a client’s personal profile and investment plan. We then create and manage the client’s investments based on that profile and plan. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals. Once we have determined the appropriate strategy for you and your family and executed the strategy, we will provide ongoing investment review and management services. This approach requires us to periodically review your portfolio. With our discretionary relationships, we will make changes to the portfolio, as we deem appropriate, to meet your financial objectives. We trade these portfolios based on the combination Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 4  of our market views and your objectives. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of particular securities. Our Firm may advise a Client about legacy positions or other investments in Client portfolios. Clients can limit or restrict our trading in these positions. Where appropriate, we provide advice about concentrated stock positions already held in client portfolios. Clients can engage us to advise them on certain investment products that are not maintained at their primary Custodian, such as annuity contracts and assets held in employer- sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. FINANCIAL PLANNING We work with all clients to understand their financial objectives. For most clients, our asset management fee includes the cost of financial planning. If more complex planning is needed, Cornerstone Advisors may charge separate fees under a Financial Planning Agreement for the preparation of a formal financial plan. Through the financial planning process, our team strives to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each family in mind, we may offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer and family legacy objectives. We partner with our clients’ other advisors (CPA, estate attorney, insurance broker, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets and periodic updates. Our specific services in preparing your formal financial plan may include: • Review and clarification of your financial goals; • Assessment of your overall financial position including cash flow, balance sheet, invest- ment strategy, risk management and estate planning; • Creation of a unique plan for each goal you have, including personal and business real es- tate, education, retirement or financial independence, charitable giving, estate planning, business succession and other personal goals; • Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, asset location, expenses, risk and liquidity factors for each goal. This includes IRA and qualified plans, taxable and trust accounts that require special attention. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 5  The recommendations for the financial plan will not be reviewed nor updated, unless requested by the client at which point a new Financial Planning Agreement between Client and Advisor may be executed. CONSULTING SERVICES We also provide clients investment advice on a more limited basis on one-or-more isolated areas of concern such as small business consulting, real estate, pension plan consulting, or any other specific topic. Additionally, we provide advice on non-securities matters about the rendering of estate planning, insurance, real estate, and/or annuity advice. All these are rendered under a Consulting Services Agreement. In these cases, we may supply recommendations, but you will be required to select your own investment managers, custodian and/or insurance companies for the implementation of consulting recommendations. If your needs include brokerage and/or other financial services, we will recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies or other financial professionals. You must independently evaluate these firms before opening an account or transacting business, and you have the right to effect business through any firm you choose. Also note, you have the right to choose whether to follow the consulting advice that we provide. DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (1) leave the money in the former employer’s plan, if permitted, (2) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (3) rollover to an Individual Retirement Account (“IRA”), or (4) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm, therefore, has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. All rollover recommendations are reviewed by our Firm’s Chief Compliance Officer and remains available to address any questions that a client or prospective client has regarding the oversight. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 6  the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. WRAP FEE PROGRAM We do not sponsor a Wrap Fee Program. ASSETS As of December 31, 2025, Cornerstone Advisors manages a total of $265,133,083 regulatory assets under management. Our firm manages $240,136,599 in discretionary assets and $24,996,484 in non-discretionary assets. ITEM 5 - FEES AND COMPENSATION INVESTMENT MANAGEMENT FEES AND COMPENSATION Our Firm charges a fee as compensation for providing Investment Management services on your account. These services include advisory services, trade execution, investment supervision, and other account-maintenance activities. Our Custodians may charge additional fees such as transaction costs, custodial fees, redemption fees, retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for more details. The fees for Investment Management are based on an annual percentage of assets under management and are applied to the household asset value on a pro-rata basis and billed quarterly in arrears. The initial fee will be based upon the market value of the portfolio on the last business day of the partial quarter, prorated based on the number of days when the Account(s) first received funds or securities during the quarter. Thereafter, the fee shall be based on the account value on the last business day of the preceding calendar quarter. The value will be determined as reported by the Custodian. Fees are assessed on all assets under management, including securities, cash and money market balances. Margin account balances are not included in the fee billing. Managed legacy positions are included within our Firm’s standard investment management fee and are outlined in the executed investment management agreement. Our maximum investment advisory fee as a percentage of assets under management is 1.00%. The specific advisory fees are set forth in your Investment Management Agreement. We may negotiate a lower advisory fee. Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account or other reasons agreed upon by us and you as the client. Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of determining the account size and annualized fee. The common practice is often referred to as “householding” portfolios for fee purposes and may result in lower fees than if fees were calculated on portfolios separately. Our method of householding accounts for fee purposes looks at the overall family dynamic and relationship. When applicable and noted in the Investment Management Agreement, concentrated stock positions may also be excluded from the fee calculation. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 7  The independent qualified Custodian holding your funds and securities will debit your account directly for the advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be paid directly from your account held by the qualified Custodian. The qualified Custodian agrees to deliver an account statement to you on at least a quarterly basis indicating all the amounts deducted from the account including our advisory fees. You may pay the advisory fees directly to our Firm by check. If you choose this method of payment, it will be noted in the Investment Management Agreement and fees are to be paid within 30 days of Client’s receipt of an invoice from Advisor. Either Cornerstone Advisors or you may terminate the Investment Management Agreement immediately upon written notice to the other party. The management fee will be pro-rated to the date of termination for the quarter in which the cancellation notice was given and the earned fee charged to your account as indicated in your Agreement. Upon termination, you are responsible for monitoring the securities in your account, and we will have no further obligation to act or advise with respect to those assets. In the event of client’s death or disability, our Firm will continue management of the account until we are notified of client’s death or disability and given alternative instructions by an authorized party. FINANCIAL PLANNING FEES We will negotiate the planning fees with you. Fees may vary based on the extent and complexity of your individual or family circumstances and the amount of your assets under our management. Our fee will be agreed upon in advance of services being performed. The fee will be determined based on factors including the complexity of your financial situation and agreed upon deliverables. Hourly fees for financial plans range from $150 to $300. A good faith estimate of the total cost will be provided. Fees are negotiable, and the final fee schedule and method of payment will be disclosed in the Financial Planning Agreement. Fees are paid in arrears upon Client’s receipt of the written recommendations. Because fees are charged in arrears, no refund is necessary. Clients may terminate their contracts without penalty or fee within five business days of signing the Financial Planning Agreement. Typically, we complete a plan within a month and will present it to you within 90 days of the contract date, if you have provided us all information needed to prepare the financial plan. Fees are billed and payable at the time the financial plan is delivered to you. CONSULTING FEES We provide consulting services for clients who need advice on a limited scope of work. We will negotiate consulting fees with you. Hourly fees range from $150 to $300 for Consulting Services and may vary based on the extent and complexity of the consulting project. Fees will be billed as services are rendered. Either party may terminate the agreement. Upon termination, fees will be prorated to the date of termination and any unearned portion of the fee will be refunded to you as described in the Agreement and our hourly rate described above. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 8  ADDITIONAL FEES AND EXPENSES In addition to the advisory fees paid to our Firm, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include securities fees, transaction fees, custodial fees, fees charged by the Independent Third-Party Money Managers, internal charges imposed directly by a mutual fund or ETF in a client’s account as disclosed in the fund’s prospectus (e.g., 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. Our brokerage practices are described at length in Item 12 below. Our Firm does not share in any of these additional fees and expenses outlined above. ADMINISTRATIVE SERVICES PROVIDED BY ADVYZON We have contracted with Advyzon to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, client database maintenance, quarterly performance evaluations, payable reports, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Advyzon will have access to client information, but Advyzon will not serve as an investment advisor to our clients. Cornerstone Advisors and Advyzon are non-affiliated companies. Advyzon charges our Firm an annual fee for each account administered by Advyzon. Please note that our management fee charged to the client will not increase due to the fee Cornerstone Advisors pays to Advyzon. The Advyzon fee is paid from the portion of the management fee retained by our Firm. *There may be a possibility for minor price or account value discrepancies due to quarter-end transactions in an account. Dividends or trade date settlements may occur and our third-party billing software may report a slight difference in account valuation at quarter end compared to what is reported on your State- ment from the Custodian. Our firm has the ability to produce billing summaries, which can be provided upon request. ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client account (so-called performance-based fees) nor engage in side-by-side management. ITEM 7 - TYPES OF CLIENTS We provide investment advice to individuals, high net worth individuals, corporations, charitable organizations, trusts, estates, and pension and profit sharing plans. We do not have a minimum initial account value. ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS METHODS OF ANALYSIS Cornerstone Advisors method of security and market analysis may include fundamental analysis as well as a review of general market and financial conditions. Our research sources include Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 9  commercial research services, financial newspapers and periodicals, and research provided by mutual fund companies. Based on each client’s current financial situation, investment objectives, risk tolerance and time horizon, Cornerstone Advisors will develop an appropriate asset allocation. Portfolios are diversified among different asset classes. We design long-term portfolios that incorporate the principles of Modern Portfolio Theory. Our investment approach is rooted in the belief that markets are relatively efficient and that investor returns are determined principally by asset allocation decisions. We build our model portfolios utilizing primarily no-load mutual funds and exchange traded funds. A client’s tolerance for risk and their long term goals will determine the allocation of their investments among cash and cash equivalents, stocks, bonds, ETFs, alternatives, REITs, municipal bonds, and structured notes. By offering to meet with our clients on a regular basis, we stay informed about changes in lifestyles or other events that may cause their goals to change over time. We take a long-term approach and generally avoid frequent trading. We will generally hold investments for at least one year, though circumstances (e.g. tax considerations, cash needs, market volatility, etc.) may sometimes dictate that an investment be sold within one year. We do not typically buy investments on margin but establish non-qualified accounts with margin to allow greater flexibility in obtaining cash and allowing time to determine which position within the account to liquidate for cash needs. Alternative investments are thought of as investments other than stocks and bonds. The alternative investment strategies we offer tend to move independently of stock and bond markets. The main goal of alternatives is to provide access to other return sources, with the potential benefits of reducing the risk of an investor’s portfolio, improving returns, or both. Our Firm may recommend alternative investments such as public non-traded real estate programs, public non-traded business development companies, private credit programs, and private real estate programs which have their own management fees and operating expenses. Therefore, these investments subject clients to Cornerstone Advisors’ direct management fee and the indirect fees of the investment. Our methods of analysis and investment strategies do not present any significant or unusual risks. However, investing in securities involves risk of loss that clients should be prepared to bear. INVESTMENT STRATEGIES Cornerstone Advisors uses long-term trading for most accounts but occasionally uses short-term trading strategies primarily for tax planning purposes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. When purchasing mutual funds, our policy is to select institutional share classes whenever possible. The institutional share class generally has the lowest expense ratio relative to other classes. Mutual fund expense ratios are in addition to our fee, and we do not receive any portion of these charges. If an institutional share class is not available or is not the optimal solution given trading frequency Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 10  and amount purchased, the advisor will purchase the least expensive share class available. As share classes with lower expense ratios become available, we may convert the existing mutual fund position to the lower cost share class. RISK OF LOSS Clients must understand that past performance is not indicative of future results. Therefore, current and prospective clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different types of investments there will be varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. Investors should be aware that accounts are subject to the following risks: Market Risk — Even a long-term investment approach cannot guarantee a profit. Economic, political and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon liquidation. Management Risk — An account is subject to the risk that judgments about the attractiveness, value, or potential appreciation of the account’s investments may prove to be incorrect. If the selection of securities or strategies fails to produce the intended results, the account could underperform other accounts with similar objectives and investment strategies. Foreign Securities and Currency Risk — Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. Capitalization Risk — Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services, and their stocks have historically been more volatile than the stocks of larger, more established companies. Interest Rate Risk — In a rising rate environment, the value of fixed-income securities generally declines and the value of equity securities may be adversely affected. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 11  Credit Risk — Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and, thus, impact the fund’s performance. Securities Lending Risk — Securities lending involves the risk that the fund loses money because the borrower fails to return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. Exchange-Traded Funds Risk — ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its “net asset value.” Alternative Mutual Fund or ETF Risk — Our models and accounts may use certain ETFs and mutual funds to invest primarily in alternative investments or strategies. Investing in these alternative investments and strategies may only be suitable for some of our Clients. These include special risks, such as those associated with commodities, real estate, and leverage, selling securities short, use of derivatives, potential adverse market forces, regulatory changes, and potential ill- liquidity. Special risks are associated with ETFs that invest principally in real estate securities, such as sensitivity to changes in real estate values or changes in interest rates and price volatility due to the ETF’s concentration in the real estate market. The risks with mutual funds include the costs and expenses within the fund that can impact performance, change of Managers, and the fund straying from its objective (i.e., style drift). Mutual funds have certain costs associated with underlying transactions and operating costs, such as marketing and distribution expenses and advisory fees. Mutual fund costs and expenses vary from fund to fund and will impact a mutual fund’s performance. Additionally, mutual funds typically have different share classes, as further discussed below, that trade at different Net Asset Values (“NAV”) as determined at the daily market close and have different fees and expenses. Performance of Underlying Managers — We select the mutual funds and ETFs in our portfolios. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. Liquidity Risk — Liquidity risk exists when particular investments would be difficult to purchase or sell, possibly preventing clients from selling such securities at an advantageous time or price. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 12  Alternative Investments Risk – Investments classified as "alternative investments" may include a broad range of underlying assets including, but not limited to, hedge funds, private equity, venture capital, and registered, publicly traded securities. Alternative investments may be speculative, not suitable for all clients and intended for only experienced and sophisticated investors who are willing to bear the high risk of the investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund; potential lack of diversification and resulting higher risk due to concentration of trading authority with a single advisor; absence of information regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher fees than other investment options such as mutual funds. Investing in a fund that concentrates its investments in a few holdings may involve heightened risk and result in greater price volatility. Real Estate Securities and Related Derivatives — increases in property taxes and operating expenses, zoning The Fund may gain exposure to the real estate sector by investing in real estate-linked derivatives, REITs, and common, preferred and convertible securities of issuers in real estate-related industries. Each of these types of investments are subject to risks similar to those associated with direct ownership of real estate, including loss to casualty or condemnation, law amendments, changes in interest rates, overbuilding and increased competition, variations in market value, and possible environmental liabilities. REITs are subject to management fees and other expenses, and so the Fund, when investing in REITs, will bear its proportionate share of the costs of the REITs’ operations. An investment in a REIT or a real estate-linked derivative instrument that is linked to the value of a REIT is subject to additional risks, such as poor performance by the manager of the REIT, adverse changes to the tax laws or failure by the REIT to qualify for tax-free pass- through of income under the Code. In addition, some REITs have limited diversification because they invest in a limited number of properties, a narrow geographic area, or a single type of property. Furthermore, REITs are not diversified because they only operate in the real estate business and are heavily dependent on cash flow. Also, the organizational documents of a REIT may contain provisions that make changes in control of the REIT difficult and time-consuming. Concentration Risk – Strategies concentrated in only a few securities, sectors or industries, regions or countries, or asset classes could expose a portfolio to greater risk. They may cause the portfolio value to fluctuate more widely than a diversified portfolio. Overexposure to certain sectors or asset classes (e.g., MLPs, REITs, etc.) may be detrimental to an investor if there is a negative sector move. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 13  Legacy Holding Risk — Investment advice may be offered on any investment a Client holds at the start of the advisory relationship. Depending on tax considerations and Client sentiment, these investments will be sold over time, and the assets invested in the appropriate strategy. As with any investment decision, there is the risk that timing with respect to the sale and reinvestment of these assets will be less than ideal or even result in a loss to the Client. Cybersecurity Risk – These risks include both intentional and unintentional events at our Firm or one of its third- party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or other misuse of confidential information. Our Firm has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because unknown threats may emerge in the future. ITEM 9 - DISCIPLINARY INFORMATION We do not have any legal, financial, or other “disciplinary” item to report. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS INSURANCE Investment Advisor Representatives (“IAR”) of Cornerstone Advisors may act as agents appointed with various unaffiliated life, disability, or other insurance companies, to receive commissions, trails, or other compensation from the respective product sponsors and/or as a result of effecting insurance transactions for clients. However, clients should note that they are never under any obligation to purchase any insurance products through Cornerstone Advisors’ IAR. IARs of our Firm do not have an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading Advisor, or an associated person of the foregoing entities. Our firm nor any of its management persons are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. ITEM 11 - CODE OF ETHICS PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our advisory personnel to mitigate conflict of interest. The Code of Ethics addresses, among other things, personal trading, gifts, the prohibition against the use of inside information. The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel regarding the firm’s expectations and laws governing their conduct, remind personnel that they are in a position of trust and must act with complete propriety at all times, protect the Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 14  reputation of Cornerstone Advisors, guard against violation of the securities laws, and establish procedures for personnel to follow so that we may determine whether their personnel are complying with the firm’s ethical principles. Our Firm and persons associated with us are allowed to invest for their own accounts or to have a financial investment in the same securities or other investments that we recommend or acquire for your account and may engage in transactions that are the same as transactions made in your account. We recognize the fiduciary responsibility to act in your best interest and have established polices to mitigate conflicts of interest. in order to ensure our firm’s fiduciary We have established the following restrictions responsibilities: • A director, officer or employee of Cornerstone Advisors shall not buy or sell any securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No supervised employee of Cornerstone Advisors shall prefer his or her own interest to that of the advisory client. Trades for supervised employees are traded alongside client accounts. • We maintain a list of all securities holdings of anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of Cornerstone Advisors. • We emphasize the unrestricted right of the client to decline to implement any advice ren- dered, except in situations where we are granted discretionary authority of the client’s account. • We require that all supervised employees must act in accordance with all applicable Fed- eral and State regulations governing registered investment advisory practices. • Any supervised employee not in observance of the above may be subject to termination. You may request a complete copy of our Code of Ethics by contacting us at the telephone number on the cover page of this Part 2; Attn: Chief Compliance Officer. ITEM 12 - BROKERAGE PRACTICES We generally recommend that our Clients utilize Charles Schwab & Co., Inc. Advisor Services ("Schwab"), a registered broker-dealer, Member SIPC, as the qualified Custodian. Our Firm is independently owned and operated and unaffiliated with Schwab. Schwab will hold Client assets in a brokerage account and buy and sell securities when our Firm instructs them. While our Firm recommends that Clients use Schwab as a Custodian, Clients must decide whether to do so and open accounts with Schwab by entering into account agreements directly with them. The Client opens the accounts with Schwab. The accounts will always be held in the Client's name and never in our Firm’s. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 15  HOW OUR FIRM SELECTS CUSTODIAN-BROKER Our Firm seeks to recommend a Custodian-Broker who will hold Client assets and execute the transactions on terms that are, overall, most advantageous compared to other available providers and their services. Our Firm considers a wide range of factors, including, among others: • Combination of transaction execution and asset custody services (generally without a sep- arate fee for custody). • Capability to execute, clear, and settle trades (buy and sell securities for Client accounts). • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc.). • The breadth of available investment products (stocks, bonds, mutual funds, exchange- traded funds [ETFs], etc.). • Availability of investment research and tools that assist us in making investment decisions. • Quality of services. • Competitiveness of the price of those services (commission rates, other fees, etc.) and will- ingness to negotiate the prices. • Reputation, financial strength, and stability. • Prior service to our Firm and our other Clients. • Availability of other products and services that benefit our Firm, as discussed below (see “Products And Services Available To Us From Schwab”). CLIENT BROKERAGE & CUSTODY COSTS For Clients' accounts, Schwab maintains and generally does not charge separately for custody services. However, Schwab receives compensation by charging ticket charges or other fees on trades it executes or settling into Clients' Schwab accounts. In addition to commissions, Schwab charges a flat dollar amount as a "prime broker" or "trade away" fee for each trade that our Firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a Client’s Schwab account. These fees are in addition to the ticket charges or compensation the Client pays the executing broker-dealer. Because of this, our Firm has Schwab execute most trades for Client accounts to minimize trading costs. Our Firm has determined that having Schwab execute most trades is consistent with our duty to seek the "best execution" of Client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see How Our Firm Selects Custodian-Broker). PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB Schwab Advisor Services™ (formerly called Schwab Institutional®) provides independent investment advisory Firms and Clients with access to its institutional brokerage, trading, custody, reporting, and related services, many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our Clients’ accounts; others help us manage and grow our business. Schwab’s support services generally are available on an unsolicited basis and at no charge to our Firm. These are typically considered soft dollar benefits because there is an incentive to do business with Schwab. Receiving Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 16  soft dollar benefits creates a conflict of interest. We have established policies in this regard to mitigate any conflicts of interest. We believe our selection of Schwab as Custodian-Broker is in the Clients' best interests. Our Firm will always act in the best interest of our Clients and act as fiduciary in carrying out services to Clients. The following is a more detailed description of Schwab’s support services: SERVICES THAT BENEFIT OUR CLIENTS Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client assets. The investment products available through Schwab include some we might not otherwise have access to or would require a significantly higher minimum initial investment by our Clients. Schwab’s services described in this paragraph generally benefit our Clients and their accounts. SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS Schwab also makes other products and services available that benefit our Firm but may not directly benefit our Clients or their accounts. These products and services assist our Firm in managing and administering our Clients’ accounts. They include investment research, both Schwab’s own and that of third parties. Our Firm may use this research to service all or a substantial number of our Client's accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provides access to Client account data (such as duplicate trade confirmations and account statements). • Facilitate trade execution and allocate aggregated trade orders for multiple Client ac- counts. • Provide pricing and other market data. • Facilitate payment of our fees from our Clients’ accounts. • Assist with back-office functions, recordkeeping, and Client reporting. SERVICES THAT GENERALLY BENEFIT ONLY US Schwab also offers other services to help our Firm manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance provid- ers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to our Firm. Schwab may also discount or waive its fees for some Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 17  of these services or pay all or a part of a third party’s fees. Schwab may also provide our Firm with other benefits, such as occasional business entertainment for our personnel. OUR INTEREST IN SCHWAB’S SERVICES • The availability of these services from Schwab benefits our Firm because we do not have to produce or purchase them. These services are not contingent upon our Firm committing any specific amount of business to Schwab in trading commissions. We believe our selec- tion of Schwab as Custodian and Broker is in our Client’s best interests. • Some of the products, services, and other benefits provided by Schwab benefit our Firm and may not benefit our Client accounts. Our recommendation or requirement that you place assets in Schwab's custody may be based, in part, on the benefits Schwab provides to our Firm or our Agreement to maintain certain Assets Under Management at Schwab and not solely on the nature, cost, or quality of custody and execution services provided by Schwab. • Our Firm places trades for our Clients' accounts subject to its duty to seek the best execu- tion and other fiduciary duties. Schwab's execution quality may be different from other broker-dealers. • Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transactions through a specified Custodian. Additionally, our Firm typically does not permit the Client to direct brokerage. We place trades for Client accounts subject to our duty to seek the best execution and other fiduciary duties. • We will aggregate trades for ourselves or our associated persons with your trades, provid- ing that the following conditions are met: o Our policy for the aggregation of transactions shall be fully disclosed sepa- rately to our existing Clients (if any) and the broker/dealer(s) through which such transactions will be placed. o We will only aggregate transactions if we believe that aggregation is con- sistent with our duty to seek the best execution (which includes the duty to seek the best price) for the Client and is consistent with the terms of our investment advisory agreement. o o No advisory Client will be favored over any other Client; each Client that participates in an aggregated order will participate at the average share price for all transactions in a given security on a given business day, with transaction costs based on each Client's participation in the transaction. o Our Firm will prepare a written statement (“Allocation Statement”) specify- ing the participating Client accounts and how to allocate the order among those Clients. If the aggregated order is filled in its entirety, it will be allocated among Clients per the allocation statement; if the order is partially filled, the ac- counts that did not receive the previous trade's positions should be "first in line" to receive the next allocation. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 18  o Notwithstanding the preceding, the order may be allocated on a basis dif- ferent from that specified if all Client accounts receive fair and equitable treatment. The reason for the difference in allocation will be documented and reviewed by our Firm’s Compliance Officer. Our Firm’s books and rec- ords will separately reflect, for each Client account, the orders which are aggregated, and the securities held by and bought for that account. o Our Firm will not receive additional compensation or remuneration of any o kind because of the proposed aggregation; and Individual advice and treatment will be accorded to each advisory Client. We may recommend that you establish accounts with Strata Trust Company, Community National Bank, or another custodian to maintain custody and to effect trades of certain alternative assets due to lower costs associated with such custody or as your needs require. You are under no obligation to act upon any recommendations, and if you elect to act upon any recommendations, you are under no obligation to place the transactions through any broker/dealer we recommend. Our recommendation is generally based on the broker’s cost and fees, skills, reputation, dependability, and compatibility with the client. You may be able to obtain lower commissions and fees from other brokers and the value of products, research and services given to us is not a factor in determining the selection of broker/dealer or the reasonableness of their commissions. BROKERAGE FOR CLIENT REFERRALS Our Firm does not receive client referrals from any Custodian or third party in exchange for using that broker-dealer or third party. TRADE ERRORS We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole and the Firm will absorb any loss resulting from the trade error if the error was caused by the Firm. If the error is caused by the Custodian, the Custodian will be responsible for covering all trade error costs. If an investment gain results from the correcting trade, the gain will be donated to charity. We will never benefit or profit from trade errors. DIRECTED BROKERAGE We do not routinely recommend, request, or require that you direct us to execute transactions through a specified broker dealer. Additionally, we typically do not permit you to direct brokerage. We place trades for your account subject to our duty to seek best execution and other fiduciary duties. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 19  ITEM 13 - REVIEW OF ACCOUNTS ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES Our Investment Advisor Representatives will monitor client accounts on a regular basis and perform annual reviews with each client. Client accounts are also reviewed periodically by the Chief Compliance Officer. All accounts are reviewed for consistency with client investment strategy, asset allocation, risk tolerance and performance relative to the appropriate benchmark. More frequent reviews may be triggered by changes in an account holder’s personal, tax or financial status. Geopolitical and macroeconomic specific events may also trigger reviews. STATEMENTS AND REPORTS The Custodian for the individual client’s account will provide clients with an account statement at least quarterly. Reports may also be provided at every client meeting. Communication to clients will be done on an as needed basis with a minimum of one contact per calendar year. You are urged to compare the reports provided by Cornerstone Advisors against the account statements you receive directly from your account Custodian. Those clients who are exclusively Consulting or Financial Planning clients (i.e. those who have no assets under management with us in our advisory program) will receive no regular reports from the Firm. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION CLIENT REFERRALS We do not pay referral fees or receive compensation for client referrals. OTHER PROFESSIONALS Our Firm may refer business to estate planning attorneys, accountants, insurance brokers, and other professionals. However, we do not receive monetary or other material compensation for referring Clients to such professionals. We also do not pay any person or firm commissions or other items of material value for referring Clients to us. If we receive or offer an introduction to a Client, we do not pay or earn a referral fee, nor are there established quid pro quo arrangements. Each Client can accept or deny such referral or subsequent services. ITEM 15 – CUSTODY Custody has been defined by regulators as having access or control over client funds and/or securities. Our firm does not have physical custody, as it applies to investment advisors. DEDUCTION OF ADVISORY FEES For all accounts, our firm has the authority to have fees deducted directly from client accounts. Our firm has established procedures to ensure all client funds and securities are held at a qualified Custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified Custodian’s name, address and the manner in which the funds or Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 20  securities are maintained. Finally, account statements are delivered directly from the qualified Custodian to each client, or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from our Firm. When you have questions about your account statements, you should contact our Firm or the qualified Custodian preparing the statement. Please refer to Item 5 for more information about the deduction of Advisor fees. STANDING LETTERS OF AUTHORIZATION (“SLOA”) Our firm is deemed to have custody of clients’ funds or securities when clients have standing authorizations with their Custodian to move money from a client’s account to a third-party (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers with the Custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. We do not have a beneficial interest on any of the accounts we are deemed to have Custody where SLOAs are on file. In addition, account statements reflecting all activity on the account(s), are delivered directly from the qualified Custodian to each client or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from us. When you have questions about your account statements, you should contact us, your Advisor or the qualified Custodian preparing the statement. ITEM 16 – INVESTMENT DISCRETION For discretionary accounts, prior to engaging Cornerstone Advisors to provide investment advisory services, you will enter a written Agreement with us granting the Firm the authority to supervise and direct, on an on-going basis, investments in accordance with the client’s investment objective and guidelines. We are authorized, in our discretion and without prior consultation with you to: (1) buy, sell, exchange and trade any stocks, bonds or other securities or assets and (2) determine the amount of securities to be bought or sold and (3) place orders with the Custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you, the client. The limitations on investment and brokerage discretion held by Cornerstone Advisors for you are: • For discretionary accounts, we require that we be provided with authority to determine which securities and the amounts of securities to be bought or sold. • Any limitations on this discretionary authority shall be in writing as indicated on the Invest- ment Management Agreement. You may change/amend these limitations as required. In some instances, we may not have discretion on an account. We will discuss all transactions with you prior to execution or you will be required to make the trades if in an employer sponsored account. ITEM 17 – VOTING YOUR SECURITIES We will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent third-party at your own discretion. You designate proxy voting authority in the Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 21  custodial account documents. You must ensure that proxy materials are sent directly to you or your assigned third party. We do not take action with respect to any securities or other investments that become the subject of any legal proceedings, including bankruptcies. Clients can contact our office with questions about a particular solicitation by phone at (785) 273-2685. ITEM 18 – FINANCIAL INFORMATION We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. Cornerstone Advisors, LLC - 6540 SW 10th Avenue Topeka, Kansas, 66615 FORM ADV 2A Brochure 22