Cornerstone Management, Inc.

Brochure Form ADV Part 2A Item 1 - Cover Page CRD# 125828 3237 Satellite Boulevard Suite 400 Duluth, Georgia 30096 (770)449-7799 www.cornerstonemgt.net July 2, 2026 This Brochure provides information about the qualifications and business practices of Cornerstone Management, Inc. If you have any questions about the contents of this Brochure, please contact us at (770)449-7799 or info@cornerstonemgt.net. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state authority. Cornerstone Management, Inc. is an investment advisory firm registered with the appropriate regulatory authority. Registration does not imply a certain level of skill or training. Additional information about Cornerstone Management, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 - Material Changes This Brochure, dated July 2, 2026, serves as an interim amendment for Cornerstone Management, Inc. Our last annual updating amendment was filed on March 26, 2026. A copy of the Summary of Material Changes from our last required annual update filing may be requested by contacting Lisa Smith at (770)449-7799 or info@cornerstonemgt.net. Page 2  Item 3 - Table of Contents Page 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 .................................................................................................................................. 8 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 .............................................................................................................................. 12 Item 10 - Other Financial Industry Activities and Affiliations ....................................................................... 12 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 12 Item 12 - Brokerage Practices ..................................................................................................................................... 13 Item 13 - Review of Accounts ...................................................................................................................................... 15 Item 14 - Client Referrals and Other Compensation .......................................................................................... 15 Item 15 - Custody .............................................................................................................................................................. 16 Item 16 - Investment Discretion ................................................................................................................................. 17 Item 17 - Voting Client Securities .............................................................................................................................. 17 Item 18 - Financial Information .................................................................................................................................. 17 Brochure Supplements…………………..………………………...………………………….……………………… Exhibit A Page 3  Item 4 - Advisory Business General Information Cornerstone Management, Inc. (“Cornerstone”) was founded in 1991 in the state of Georgia and provides investment advisory services to clients across the United States. Cornerstone is located in the greater Atlanta region and is privately owned. Bryan C. Taylor and Tamara S. Richwine are the principal shareholders. Please see Brochure Supplements, Exhibit A, for more information on these and other individuals who formulate investment advice and have direct contact with clients, or have discretionary authority over client accounts. As of December 31, 2025, Cornerstone had $2,286,345,234 in assets under management, of which $2,286,026,428 is managed on a discretionary basis and $318,806 is managed on a non- discretionary basis. As of the same date, Cornerstone had Assets under Advisement of $153,812,777. SERVICES PROVIDED At the outset of each client relationship, we spend time with you, asking questions, discussing your investment experience and financial circumstances, and reviewing options for you. Based on our review, we generally develop: • a financial outline for you based on your financial circumstances and goals and your risk tolerance level (the “Financial Profile” or “Profile”); and • your investment objectives and guidelines (the “Investment Plan” or “Plan”). The Financial Profile is a reflection of your current financial picture and a look to your future goals. The Investment Plan outlines the types of investments we will make or recommend on your behalf to meet those goals. The Profile and the Plan are discussed regularly with you, but are not necessarily written documents. Portfolio Management As described above, at the beginning of a client relationship, we meet with you, gather information, and perform research and analysis as necessary to develop your Investment Plan. Your Investment Plan includes an asset allocation strategy for implementation. The Investment Plan will be updated from time to time when requested by you, or when determined to be necessary or advisable by us based on updates to your financial or other circumstances. To implement your Investment Plan, we will manage your investment portfolio on a discretionary or a non-discretionary basis. As a discretionary investment adviser, we will have the authority to supervise, direct, and manage your portfolio without prior consultation with you. Under a non-discretionary arrangement, you must be contacted prior to the execution of any trade in your account(s) under management. This can result in a delay in executing recommended trades, which could adversely affect the performance of your portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, you retain the responsibility for the final decision on all actions taken with respect to the portfolio. Notwithstanding the foregoing, you may impose certain reasonable written restrictions on us in the management of your investment portfolios, such as prohibiting the inclusion of certain types of Page 4  investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. You should note, however, that restrictions imposed by you may adversely affect the composition and performance of your investment portfolio. You should also note that your investment portfolio is treated individually by giving consideration to each purchase or sale for your account. For these and other reasons, performance of your investment portfolio within the same investment objectives, goals and/or risk tolerance may differ and you should not expect that the composition or performance of your investment portfolio would necessarily be consistent with similar clients of ours. for you. Factors that we consider Separate Account Managers When appropriate and in accordance with the Investment Plan for you, we may recommend the use of one or more Separate Account Managers, each a “SAM.” Having access to various SAMs offers a wide variety of manager styles and offers clients the opportunity to utilize more than one SAM if necessary to meet the needs and investment objectives of the client. We will select or recommend the SAM(s) we deem most appropriate in recommending/selecting SAMs generally include your stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing and research. The SAM(s) will be granted discretionary trading authority to provide investment supervisory services for your portfolio, but we normally retain the discretionary authority to terminate the SAM’s relationship or to add new SAMs without your specific consent. With respect to assets managed by a SAM, our role will be to monitor your overall financial situation, to monitor the investment approach and performance of the SAM(s), and to assist you in understanding the investments of your portfolio. Additionally, certain SAMs may impose more restrictive account requirements than us and billing practices may vary. In such instances, we may be required to alter our corresponding account requirements and/or billing practices to accommodate those of the SAM(s). Institutional Client Services Cornerstone provides comprehensive investment consulting and administrative services to charitable organizations. As an Outsourced Chief Investment Officer (“OCIO”) to nonprofit organizations, we utilize a consulting-based approach to develop a customized service offering based on each client’s specific needs and priorities. When we serve as an OCIO, Cornerstone acts as a co-fiduciary with the institutional client. Cornerstone’s administrative services focus on the planned gift administration needs of our institutional clients. Our available administrative services include distribution processing, customized reporting, trust and gift annuity administration, annual tax form preparation and state regulation compliance for various planned gift vehicles such as charitable trusts, charitable gift annuities and donor advised funds. Financial Planning We offer limited financial planning services to those clients in need of such service in conjunction with Portfolio Management services. Our limited financial planning services normally address areas such as general cash flow planning, retirement planning and insurance analysis. The goal of this service is to assess your financial circumstances in order to more effectively develop your Investment Plan. Page 5  General Consulting In addition to the foregoing services, we may provide general consulting services to you. These services are generally provided to institutional clients on a project basis to include matters specific to you as and when requested by you and agreed to by us. The scope and fees for consulting services will be negotiated with you at the time of engagement for the applicable project. Individual Retirement Advice When we are making investment recommendations to you regarding your retirement plan account or individual retirement account, we are acting as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money or otherwise are compensated creates some conflicts with your financial interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice) to you; • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than what is reasonable for our services; and • Give you basic information about our conflicts of interest. Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. We will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, Cornerstone will be considered a fiduciary under ERISA. For example, we will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain us to act as an investment manager within the meaning of ERISA § 3(38), we will provide discretionary investment management services to the Plan. Page 6  Fiduciary Consulting Services • Investment Selection Services We will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c). • Non-Discretionary Investment Advice We provide Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding asset classes and investments. Fiduciary Management Services • Investment Management via Model Portfolios We will provide discretionary management of Model Portfolios among which the participants may choose to invest as Plan options. Plan Participants will also have the option of investing only in options that do not include Model Portfolios (i.e., the Plan Participants may elect to invest in one or more of the mutual fund options made available in the Plan and choose not to invest in the Model Portfolios at all). Non-Fiduciary Services • Participant Education We will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages us for such services. Plan Participants are responsible for implementing transactions in their own accounts. Stewardship Training Resources Worthy of the Gift Journey – We offer an online training course which seeks to help nonprofit organizations develop a relational approach to fundraising. This journey is designed to guide participants through the process of assessing organizational “worthiness” as the foundation for fundraising. Cornerstone retains full ownership of the intellectual property and receives the net revenue share from the sale of licenses. Worthy of the Gift: Equipping Your Organization to Secure a Transformational Gift – We have engaged an independent publishing house to publish a book written by Bryan C. Taylor, based upon the Worthy of the Gift training materials. Cornerstone retains full ownership of the intellectual property and receives the net revenue share from book sales. Revenue from Stewardship Training Resources is separate and distinct from the advisory, portfolio management, consulting and administration fees we charge as detailed in Item 5. Page 7  Item 5 - Fees and Compensation General Fee Information Fees paid to us are exclusive of all custodial and transaction costs paid to your custodian, brokers or Please see Item 12 - Brokerage Practices for additional other third-party consultants. information. Fees paid to us are also separate and distinct from the fees and expenses charged by mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders (generally including a management fee and fund expenses, as described in each fund’s prospectus or offering materials). You should review all fees charged by funds, brokers, Cornerstone and others to fully understand the total amount of fees paid by you for investment and financial-related services. Investment Advisory Fees Cornerstone receives an advisory fee based on the total market value of the assets you place under our management (the “Client Account”). Advisory fees are calculated in accordance with the fee schedule set forth in the written investment advisory agreement between you and Cornerstone. Please note our fees generally have “tiers,” meaning that if your assets exceed the maximum of the first tier, your overall fee will be a blended percentage rate that is the result of being charged the corresponding fee for the first level of assets, plus the different corresponding fee for the next level of assets, and so on. The maximum current applicable advisory fee rate is 1% per annum of the market value of the Client Account. The annual fee schedule is generally structured using a graduated scale starting at 1% and declining thereafter to 0.50%. We may, at our discretion, make exceptions to the foregoing or negotiate special fee arrangements where we deem appropriate under the circumstances: • We may impose a minimum portfolio value and/or a minimum fee. • Institutional clients may pay different fees than retail clients based upon account size and client-specific consulting needs and administrative services. • Associated persons of the firm and their friends and family may participate at no fees or less than stated fees. Advisory fees will be paid quarterly in arrears based on ending period market valuations. This means that we will bill your account at the end of each quarter. If management begins after the start of a quarter, fees will be prorated accordingly. Cornerstone’s billing system adjusts fee calculations for time-weighted, capital flows (inflows and outflows) during the billing quarter. With your authorization and unless other arrangements are made, fees are normally debited directly from your account(s). investment management services. Our annual asset-based advisory fee generally includes all investment policy development, asset allocation planning and Depending on the specific circumstances, we or another manager may collect the entire fee and then allocate each party’s share according to specific arrangements agreed to by you. Either you or Cornerstone may terminate your Investment Advisory Agreement at any time, subject to any written notice requirements in the agreement. In the event of termination, final fees will be prorated based on the number of days that the account was managed, and any fees due to us from you will be invoiced or deducted from your account. Page 8  Separate Account Manager Fees The fee will vary somewhat depending on the SAM(s) used, but generally are such that, in combination with our fee, the total does not exceed 2.00% annually. As previously disclosed, SAM fees may be collected using different billing practices. In instances where the services of one or more SAMs are utilized, the fee will be charged in addition to our fee and will be detailed in the Agreement(s) signed by you. General Consulting Fees When we provide general consulting services to institutional clients, these services are generally separate from our other investment advisory services. Fees for general consulting are negotiated at the time of the engagement for such services. General consulting fees are normally assessed as a flat fee of up to $50,000. Planned Gift Administration Fees When we provide gift administration services to institutional clients, these services are separate from our other investment advisory services. Fees for planned gift administration are calculated in accordance with the fee schedule set forth in the written agreement between you and Cornerstone and are generally billed separately from investment advisory fees. Planned gift administration fees are typically calculated as a percentage of assets under administration, starting at 0.75% annually and declining thereafter. When a flat fee is agreed to by the client, the annual fee as a percentage of assets under administration may be higher than 0.75% annually. Item 6 - Performance-Based Fees and Side-By-Side Management We do not have any performance-based fee arrangements. “Side-by-Side Management” refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time manages other accounts for which fees are assessed on a performance fee basis. Because we have no performance-based fee accounts, we have no side-by- side management. Item 7 - Types of Clients We serve charitable organizations, individuals, pension and profit-sharing plans, trusts and estates. We may impose a minimum portfolio value and/or a minimum fee for investment advisory services. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis In accordance with the Investment Plan, we generally select Separate Account Managers, mutual funds and ETFs (“pooled investment funds”), stocks, bonds and alternative investments for client accounts. We have a comprehensive process for monitoring, evaluating and selecting the Separate Account Managers and pooled investment funds utilized. We employ several outside research firms to help narrow the field of choices. Some of these teams produce lists of SAMs or funds for review while others provide additional analytical information. The process of Manager selection and evaluation is enhanced by high-level relationships and strategic alliances with some of the largest custodians, broker dealers and research firms in the country. We develop these relationships to gain key insights into the economy, as well as Page 9  sophisticated analysis and manager selection capabilities. Software and database vendors such as FactSet, iCapital, CAIS and Morningstar Direct provide additional data and screening services for thousands of SAMs, pooled investment funds and alternative asset strategies. With over 10,000 managers in the U.S. alone, we begin by utilizing a combination of third-party research and quantitative screening to reduce the universe of managers to a reasonable size. Track record data, peer group analysis, social screening and manager continuity are just some of the criteria that are utilized when evaluating a prospective manager. It is our responsibility to monitor managers, and when there is a significant style drift, management change or stock selection program change, the relationship may be terminated. ETFs and mutual funds are primarily used to invest in specifically targeted areas of the U.S. Equity market or for access to foreign investments. These securities are generally evaluated and selected based on a variety of factors, including, without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings for safety and returns, and other factors. Fixed income investments may be used as a strategic investment, as an instrument to fulfill liquidity or income needs in a portfolio, or to add a component of capital preservation. We will generally evaluate and select individual bonds or bond funds based on a number of factors including, without limitation, credit rating, yield and duration. Investment Strategies Our strategic approach is to invest your portfolio in accordance with the Investment Plan that has been developed specifically for you. This means that the following strategies may be used in varying combinations over time for you, depending upon your individual circumstances. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Short Sales – a securities transaction in which an investor sells securities he or she borrowed in anticipation of a price decline. The investor is then required to return an equal number of shares at some point in the future. A short seller will profit if the stock goes down in price. Margin Transactions – a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Options Trading/Writing – a securities transaction that involves buying or selling (writing) an option. If you write an option and the buyer exercises the option, you are obligated to purchase or deliver a specified number of shares at a specified price at the exercise of the option regardless of the market value of the security at expiration of the option. Buying an option gives you the right to purchase or sell a specified number of shares at a specified price until the date of expiration of the option regardless of the market value of the security at expiration of the option. Page 10  Risk of Loss While we seek to diversify your investment portfolio across various asset classes consistent with your Investment Plan in an effort to reduce risk of loss, all investment portfolios are subject to risks. Accordingly, there can be no assurance that your investment portfolio will be able to fully meet your investment objectives and goals, or that investments will not lose money. Below is a description of several of the principal risks that your investment portfolio faces. Management Risks. While we manage your investment portfolio, or recommend one or more SAMs, based on our experience, research and proprietary methods, the value of your investment portfolio will change daily based on the performance of the underlying securities in which they are invested. Accordingly, your investment portfolio is subject to the risk that we or a SAM allocates your assets to individual securities and/or asset classes that are adversely affected by unanticipated market movements and the risk that our specific investment choices, including selection of Separate Account Managers, could underperform their relevant indexes. Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above, we may invest your portfolio in mutual funds, ETFs and other investment pools. Investments in pooled investment funds are generally less risky than investing in individual securities because of their diversified portfolios; however, these investments are still subject to risks associated with the markets in which they invest. In addition, pooled investment funds’ success will be related to the skills of their particular managers and their performance in managing their funds. Pooled investment funds are also subject to risks due to regulatory restrictions applicable to registered investment companies under the Investment Company Act of 1940. Equity Market Risks. We may invest portions of your assets directly into equity investments, either stocks or pooled investment funds that invest in the stock market. As noted above, while pooled investments have diversified portfolios that may make them less risky than investments in individual securities, funds that invest in stocks and other equity securities are nevertheless subject to the risks of the stock market. These risks include, without limitation, the risks that stock values will decline due to daily fluctuations in the markets and that stock values will decline over longer periods (e.g., bear markets) due to general market declines in the stock prices for all companies, regardless of any individual security’s prospects. Fixed Income Risks. We may invest portions of your assets directly into fixed income instruments, such as bonds and notes, or may invest in pooled investment funds that invest in bonds and notes. While investing in fixed income securities, either directly or through pooled investment funds, is generally considered to be less volatile than investing in the stock market, they nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default by borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance to maturity). Foreign Securities Risks. We may invest portions of your assets into pooled investment funds that invest internationally. While foreign investments are important to the diversification of your investment portfolio, they carry risks that may be different from U.S. investments. For example, foreign investments may not be subject to uniform audit, financial reporting or disclosure standards, practices or requirements comparable to those found in the U.S. Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in investment or exchange control regulations. Finally, foreign investments may involve currency risk, which is the Page 11  risk that the value of the foreign security will decrease due to changes in the relative value of the U.S. dollar and the security’s underlying foreign currency. Item 9 - Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Cornerstone or the integrity of our management. We have no disciplinary events to report. Item 10 - Other Financial Industry Activities and Affiliations Neither Cornerstone nor its Management Persons has any other financial industry activities or affiliations to report. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Trading We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon request. Our Code has several goals. First, the Code is designed to assist us in complying with applicable laws and regulations governing our investment advisory business. Under the Investment Advisers Act of 1940, we owe fiduciary duties to our clients. Pursuant to these fiduciary duties, the Code requires persons associated with us (managers, officers and employees) to act with honesty, good faith and fair dealing in working with clients. In addition, the Code prohibits such associated persons from trading or otherwise acting on insider information. Next, the Code sets forth guidelines for professional standards for our associated persons. Under the Code’s Professional Standards, we expect our associated persons to put the interests of our clients first, ahead of personal interests. In this regard, our associated persons are not to take inappropriate advantage of their positions in relation to our clients. Third, the Code sets forth policies and procedures to monitor and review the personal trading activities of access persons (who have access to client trading information). From time to time our access persons may invest in the same securities recommended to you. Under our Code, we have adopted procedures designed to reduce or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading policies include procedures for limitations on personal securities transactions of access persons, reporting and review of such trading and pre-clearance of certain types of personal trading activities. These policies are designed to discourage and prohibit personal trading that would disadvantage clients. The Code also provides for disciplinary action as appropriate for violations. Participation or Interest in Client Transactions Because access persons may invest in the same securities as those held in client accounts, we have established a policy requiring our access persons to pre-clear transactions in some types of securities with the Chief Compliance Officer. The goal of this policy is to avoid any conflicts of interest that arise in these situations. Some types of securities, such as CDs, treasury obligations and open-end mutual funds, are exempt from this pre-clearance requirement. However, in the event of other identified potential trading conflicts of interest, our goal is to place client interests first. Consistent with the foregoing, we maintain policies regarding participation in initial public offerings (“IPOs”) and private placements in order to comply with applicable laws and avoid Page 12  conflicts with client transactions. If an access person wishes to participate in an IPO or invest in a private placement, he or she must submit a pre-clearance request and obtain the approval of the CCO. Finally, if access persons trade with client accounts (i.e., in a bundled or aggregated trade) and the trade is not filled in its entirety, the access person’s shares will be removed from the block, and the balance of shares will be allocated among client accounts in accordance with our written policy. From time to time, you may be invited to invest in limited partnerships or other private placement opportunities in which our employees invest or have some other ownership or influence. Item 12 - Brokerage Practices Best Execution and Benefits of Brokerage Selection When given discretion to select the brokerage firm that will execute orders in client accounts, we seek “best execution” for client trades, which is a combination of a number of factors, including, without limitation, quality of execution, services provided and commission rates. Therefore, we may use or recommend the use of brokers who do not charge the lowest available commission in the recognition of research and securities transaction services, or quality of execution. Research services received with transactions may include proprietary or third-party research (or any combination) and may be used in servicing any or all of our clients. Therefore, research services received may not be used for the account for which the particular transaction was effected. Through a careful selection process, we have identified a limited number of firms (“the Custodians”) that provide custodial and/or brokerage services to the clients of investment advisers. We review each client’s individual circumstances and planned investment program and recommend the Custodian that we feel is most appropriate to meet those needs. Although we may recommend that you establish an account at a specific Custodian, it is ultimately your decision to custody assets with the Custodian. We are independently owned and operated and are not affiliated with the Custodians. The Custodians provide us with access to institutional trading, custody, reporting and related services, which are typically not available to the Custodians’ retail investors. The Custodians also make available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them. These services are not soft dollar arrangements, but are part of the institutional platform offered by the Custodians. The Custodians’ brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in their custody, the Custodians generally do not charge separately for custody services but are compensated by account holders through commissions or other fees on trades that they execute or that settle into the Custodian’s account. Certain trades may not incur the Custodian’s commissions or transaction fees. The Custodians are also compensated by earning interest on the uninvested cash in your account. The Custodians also make available to us other products and services that benefit us but may not directly benefit our clients’ accounts. Many of these products and services may be used to service all or a substantial number of our accounts, including accounts not maintained at the Custodians. Page 13  The Custodians’ products and services that assist us in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide pricing and other market data; (iv) facilitate payment of our fees from our clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting. The Custodians also offer other services intended to help us manage and further develop our business enterprise. These services may include: (i) technology, compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. The Custodians may make available, arrange and/or pay third-party vendors for the types of services rendered to us. The Custodians may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to us. The Custodians may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend that clients custody their assets at the Custodians, we may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers and not solely on the nature, cost or quality of custody and brokerage services provided by the Custodians, which may create a potential conflict of interest. Research and Soft Dollars We do not accept soft dollar payments, a common industry practice in which the transaction fees that clients pay are used to purchase research or other products that are useful to a Registered Investment Adviser. Directed Brokerage We do not generally accept directed brokerage arrangements. However, if allowed and a client wishes to direct brokerage, we may be unable to achieve the most favorable execution of client transactions. Additionally, clients directing brokerage may incur additional costs including, but not limited to, higher brokerage costs due to the inability to aggregate orders and less favorable pricing on certain securities. Trade Aggregation Clients understand and agree that at our discretion, we may aggregate purchases or sales of the same security completed on the same day on behalf of more than one client, subject to the aggregation being in the best interests of all participating clients. When transactions are so aggregated (i.e., blocked or bunched), (i) actual prices applicable to the aggregated order will be averaged, and each account participating in the aggregated order will be deemed to have purchased or sold its share of the security or instrument involved at such average price, and (ii) all transaction costs incurred in completing such an aggregated order will be shared on a pro-rata basis among all accounts participating in that aggregated order. To the extent we determine to aggregate client orders for the purchase or sale of securities, including securities in which our supervised persons may invest, we do 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. We do not receive any additional compensation or remuneration as a result of the aggregation. Page 14  If we cannot obtain execution of all the combined orders at prices or for transactions costs that we believe are desirable, we will allocate the securities bought or sold as part of the combined orders by following our order allocation procedures. Our block trading policy and procedures include the following: • • Prior to entry of an aggregated order, an order ticket (“Allocation Statement”) must be completed which identifies each client account participating in the order and the proposed allocation of the order, upon completion, to those clients. If the order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated pro rata among the participating client accounts in accordance with the Allocation Statement. However, adjustments to this pro rata allocation may be made if all client accounts receive fair and equitable treatment and the reason for the different allocation is explained in writing and is approved by an appropriate individual/officer of Cornerstone. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket charges in smaller accounts. • Cornerstone’s client account records separately reflect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, that account. • Funds and securities for aggregated orders are clearly identified on Cornerstone’s records and to the broker-dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. • No client or account will be favored over another. In some cases, certain client accounts may be excluded from aggregated block trades due to legal or regulatory concerns, client restrictions or other reasons, as determined by the CCO or designee. Item 13 - Review of Accounts We monitor managed portfolios continuously and will periodically rebalance your portfolio to the target allocation or recommend changes when deemed necessary. Your portfolio may also be reviewed if requested by you, upon receipt of information material to the management of your portfolio, or at any time such review is deemed necessary or advisable by us. These factors generally include but are not limited to, the following: change in your general circumstances (marriage, divorce, retirement); or economic, political or market conditions. Principals or Portfolio Managers of ours, either independently or together, review all accounts. Account custodians are responsible for providing monthly or quarterly account statements which reflect the positions (and current pricing) in each account as well as transactions in each account, including fees paid from an account. Account custodians also provide prompt confirmation of all trading activity, and year-end tax statements, such as 1099 forms. In addition, we provide at least an annual report for each managed portfolio. This written report normally includes a summary of portfolio holdings and performance results. Additional reports are available at your request. Item 14 - Client Referrals and Other Compensation As noted above, we receive an economic benefit from the Custodians in the form of support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at the Custodians. These products and services, how they Page 15  benefit our firm, and the related conflicts of interest are described in Item 12 - Brokerage Practices. The availability of the Custodians’ products and services to us is based solely on our participation in the programs and not on the provision of any particular investment advice. From time to time, we may enter into arrangements with third parties (“Promoters”) to identify and refer potential clients to us. Consistent with legal requirements under the Investment Advisers Act of 1940, as amended, we enter into written agreements with Promoters under which, among other things, we or the Promoter are required to disclose to you how the Promoter is compensated and any material conflicts of interest at the time that our services are recommended or endorsed by the Promoter. Item 15 - Custody It is the account custodian’s responsibility to provide you with confirmations of trading activity, tax forms and at least quarterly account statements. You are advised to review this information carefully and to notify us of any questions or concerns. You are also asked to promptly notify us if the custodian fails to provide statements on each account held. From time to time and in accordance with our agreement with you, we will provide additional reports. The account balances reflected on these reports should be compared to the balances shown on the brokerage statements to ensure accuracy. There may at times be small differences that could be due to a number of things, including the timing of dividend reporting, pending trades and differences in pricing information from various reporting agencies. Upon request, we will assist in establishing standing authorization at the custodian for Cornerstone to move money to a third party on your behalf. This standing authorization is limited to transfers where you specify the payee and all of the destination account information at the time of the authorization. Cornerstone is only authorized to direct the amount or timing of the payments. Due to this standing authorization, Cornerstone is deemed to have custody for reporting purposes on Form ADV, Part 1A, Item 9A. Cornerstone has implemented procedures to comply with the requirements outlined by the SEC in its February 21, 2017, No-Action Letter to the Investment Adviser Association and is not required to have an annual surprise examination on these assets. Furthermore, as part of the administration of the various planned gift portfolios we manage for many of our institutional clients, upon request, we are authorized by the client to effect third party payments from client account(s) and to designate the payee. We are deemed to have full custody of these accounts and all custodial accounts directly linked to them and are subject to the annual surprise examination requirement. Cornerstone has secured an independent accounting firm to conduct the annual surprise examination. In these cases where Cornerstone has full custody of client account(s), upon client instruction, we process payments from the client’s account to the donors, income beneficiaries, charities, or tax agencies in accordance with the governing agreement (such as the gift annuity contract, trust document, or donor advised fund sponsor guidelines.) We have implemented multiple controls - such as client review of payment files, periodic administrative reporting which reconciles all distributions, and internal review by a secondary Cornerstone employee - to safeguard client assets. Page 16  An annual review of all disbursement authority is performed by our compliance and gift administration teams to identify any potential changes to this authority or the inclusion of additional accounts for the annual surprise examination. Item 16 - Investment Discretion As described in Item 4 - Advisory Business, we will accept clients on either a discretionary or non- discretionary basis. For discretionary accounts, a Limited Power of Attorney (“LPOA”) is executed by you, giving us the authority to carry out various activities in your account, generally including the following: trade execution; the ability to request checks on your behalf; and, the withdrawal of advisory fees directly from your account. We then direct investment of your portfolio using our discretionary authority. You may limit the terms of the LPOA to the extent consistent with your investment advisory agreement with us and the requirements of your custodian. For non-discretionary accounts, you also generally execute an LPOA, which allows us to carry out trade recommendations and approved actions in your portfolio. However, in accordance with the investment advisory agreement between you and Cornerstone, we do not implement trading recommendations or other actions in your account unless and until you have approved the recommendation or action. As with discretionary accounts, you may limit the terms of the LPOA, subject to our agreement with you and the requirements of your custodian. Item 17 - Voting Client Securities As a policy and in accordance with our client agreement, we do not vote proxies related to securities held in your accounts. The custodian of your account will normally provide proxy materials directly to you. You may contact us with questions relating to proxy procedures and proposals; however, we generally do not research particular proxy proposals. We will utilize the services of Chicago Clearing Corporation to monitor and file litigation cases on behalf of our clients, so long as you have consented to this participation. Item 18 - Financial Information We do not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Page 17