Crossgate Wealth Advisors, LLC

Crossgate Wealth Advisors, LLC Form ADV Part 2A Brochure Cover Page Effective: March 10, 2026 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Crossgate Wealth Advisors, LLC (“Crossgate” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact us at (215) 860-2234 or by email at john@crossadvisors.com. Crossgate is a registered investment advisor with the U.S. Securities and Exchange Commissions (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Crossgate to assist you in determining whether to retain the Advisor. Additional information about Crossgate and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our firm (CRD# 121856/SEC#:801-80475). Crossgate Wealth Advisors, LLC 125 Pheasant Run, Suite 100 Newtown, PA 18940Phone: (215) 860-2234 Email: john@crossadvisors.com Web: www.crossadvisors.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about Advisory Persons of Crossgate. Crossgate believes that communication and transparency are the foundation of its relationship with Clients and will continually strive to provide its Clients with complete and accurate information at all times. Crossgate encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us. And of course, we always welcome your feedback. This Item will discuss only specific material changes that are made to the Disclosure Brochure and provide Clients with a summary of such changes. Material Changes There have been no material changes to this Disclosure Brochure since the last filing and distribution to Clients. Certain non-material changes have been made at Item 4 regarding our advisory services ANY QUESTIONS: Crossgate’s Chief Compliance Officer, John D. Rea, remains available to address any questions regarding the above changes, or any other issue pertaining to this Brochure. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Crossgate. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 121856. You may also request a copy of this Disclosure Brochure at any time by contacting us at (215) 860-2234 or by email at john@crossadvisors.com. Page 2 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Item 1 – Cover Page ............................................................................................................... 1 Item 2 – Material Changes ..................................................................................................... 2 Item 4 – Advisory Services ..................................................................................................... 4 A. Firm Information ................................................................................................................. 4 B. Advisory Services Offered .................................................................................................. 4 C. Client Account Management .............................................................................................. 7 D. Wrap Fee Programs ..........................................................................................................11 E. Assets Under Management ...............................................................................................12 Item 5 – Fees and Compensation ......................................................................................... 12 A. Fees for Advisory Services ................................................................................................12 B. Fee Billing .........................................................................................................................13 C. Other Fees and Expenses .................................................................................................13 D. Advance Payment of Fees and Termination ......................................................................13 E. Compensation for Sales of Securities ................................................................................14 Item 6 – Performance-Based Fees and Side-By-Side Management ........................................ 14 Item 7 – Types of Clients ...................................................................................................... 14 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................. 14 A. Methods of Analysis ..........................................................................................................14 B. Risk of Loss .......................................................................................................................16 Item 9 – Disciplinary Information ......................................................................................... 17 Item 10 – Other Financial Industry Activities and Affiliations ................................................ 17 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 18 Item 12 – Brokerage Practices .............................................................................................. 19 Item 13 – Review of Accounts .............................................................................................. 20 Item 14 – Client Referrals and Other Compensation ............................................................. 21 A. Compensation Received by Crossgate ..............................................................................21 B. Compensation for Client Referrals .....................................................................................21 Item 15 – Custody ................................................................................................................ 21 Item 16 – Investment Discretion .......................................................................................... 21 Item 17 – Voting Client Securities ........................................................................................ 22 Item 18 – Financial Information ........................................................................................... 22 Page 3 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Item 4 – Advisory Services A. Firm Information Crossgate Wealth Advisors, LLC (“Crossgate” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Crossgate is organized as a Limited Liability Company (“LLC”) under the laws of the Commonwealth of Pennsylvania, effective August 2016. Crossgate opened its doors on February 1, 2001 as a sole proprietorship for the purpose of providing affordable financial advice to individuals, couples and families. John D. Rea (President and Chief Compliance Officer) owns 30% of the firm, Barbara Rea (Vice President) owns 30% of the firm and Nickolaus C. von Dohlen owns 40% of the firm. Mr. Rea is responsible for managing and setting firm policy as well as supervising all of the firm's activities. In September 2016, Crossgate began to operate under the new LLC. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Crossgate. B. Advisory Services Offered Crossgate provides discretionary investment advisory services on a fee-only basis. Crossgate's annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Crossgate), Crossgate may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. To commence the investment advisory process, Crossgate will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, Crossgate provides ongoing supervision of the account(s). Before engaging Crossgate to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Crossgate setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Crossgate provides two types of services: financial planning and investment advisory services to individuals, high net worth individuals, trusts and estates (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Financial Planning Services To the extent requested by a client, Crossgate will generally offer to provide a variety of financial planning services to individuals and families as part of the advisory engagement referenced above, or on a stand- alone basis pursuant to the terms and conditions of a written financial planning agreement and a separate fee. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Financial planning services can include advice on specific financial topics that are relevant to individuals, couples and families. These topics include: investment planning, 1. budget and cash flow analysis, 2. 3. education expense funding, Page 4 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  tax analysis and planning, retirement planning, insurance needs, and 4. 5. 6. 7. estate planning. Depending upon the scope of the services to be provided, we generally follow a seven-step process widely recognized by the financial planning community. The process is as follows: identify and select goals, implement the recommendations; and 1. understand the client’s personal and financial circumstances, 2. 3. analyze the client’s current course of action and potential alternative course(s) of action, 4. develop recommendations and alternatives, 5. present the recommendations 6. 7. monitor the progress and update as required. We typically meet with a Client at the beginning of the process. Unless engaged on a stand-alone separate financial planning engagement basis, there is no charge or obligation for the first meeting. The purpose of the meeting is for us to learn about the Client's needs and goals and to inform the Client about our policies and procedures. If engaged on a separate stand-alone basis, we present an estimate of the fees for the work that we propose to do. More details about the financial planning fees can be found in the next section Item 5 - Fees and Compensation. We also request that the Client complete a comprehensive questionnaire that asks for the Client's goals, income, expenses, assets, insurance summary and miscellaneous questions about these items. Depending upon the scope of the services to be provided, after receiving the Client's information, we may prepare an investment summary. This is a report, which categorizes a Client's investments by account and by the type of investment. The report also includes performance information. We use this report to analyze the quality of investments in the Client's portfolio, the diversity within the portfolio and the overall allocation by asset class. After analyzing the portfolio, we prepare recommendations if needed to change the portfolio and a report that shows the portfolio by investment as if the recommendations were implemented. We use a computer program to analyze a Client's personal financial situation. This program presents current cash flow and net worth statements. It also provides reports that help us analyze retirement spending projections, insurance needs and future estate taxes if applicable. Once the current information is entered into this program, alternative scenarios can be constructed to illustrate other potential outcomes. Some of these reports will be printed in advance of the follow up meeting. Additional scenarios can be presented during the follow up meeting if requested by the Client. At the conclusion of the follow up meeting, we will discuss with the Client the required steps to implement the recommendations. We will also provide information on how we can assist in the implementation and the cost associated with our efforts. The recommendation may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment advisory services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Page 5 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Investment Advisory Services Crossgate provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary or non-discretionary investment management and related advisory services. This type of engagement can include the following services: 1. recommendations and implementations for portfolio investments and an appropriate asset allocation, 2. assistance in implementing the recommendations, 3. preparation of an investment policy statement that is tailored to the Client's situation, 4. continual oversight of the investments in the portfolio and the asset allocation, 5. quarterly reports that provide a summary of the capital markets and a personal review of the Client's portfolio, financial planning for relevant topics listed under Financial Planning Services, If practical, an annual meeting, so that we are aware of all relevant changes in the Client's life, 6. 7. access to FinHub™ client portal, 8. 9. phone calls and additional meetings if needed and 10. year-end review of the Client's portfolio to consider tax issues. To begin the relationship, we gather information using the same methods as mentioned above. This service begins with an initial one-hour meeting with the Client at no charge. At the end of the meeting or within a few days, we will present the Client with an estimate of the fees for the service. A more detailed description of the fees is in Item 5 - Fees and Compensation below. We will prepare recommendations for investments in the portfolio and present them to the Client. Once the Client agrees with the recommendations, we prepare an action plan that lists the items that need to be done to implement the action plan. There may be items that the Client has to perform and other items that Crossgate has to perform. We will watch over the process to make sure everything is completed. Crossgate will provide investment advisory services and related services. Under certain circumstances, Crossgate may accept or maintain custody of Client’s funds or securities. Please see Item 15 – Custody for more information. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. For additional information, please see Item 12 - “Brokerage Practices”. Investments Clients are free to restrict investments from certain industries or activities. Clients can also request investments be directed towards specific industries or activities. Examples include requests to invest in socially or Biblically responsible companies or the green energy industry (solar or wind power)-see below. Clients may restrict investments from companies that engage in gun manufacturing, gambling or the sale of alcoholic beverages. We will do our best to accommodate the Client. We will also inform the Client of the potential impact to the cost of managing the portfolio or the diversification of the portfolio for the implementation of any investment restriction. Depending upon the client’s objectives, Crossgate generally recommends and utilizes mutual funds and exchange traded funds that invest in various asset classes, including, but not limited to, corporate bonds, United States government securities, municipal securities, and individual stocks. Our management of a portfolio is considered discretionary, which means that the Advisor does not require any prior approval from Client for all transactions to be executed. We customize each portfolio to meet the needs of the Client. In the initial meeting and on an ongoing basis, we will help determine a Client's tolerance for risk. Through asking various questions, we try to ascertain Page 6 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  how sensitive a Client is to short-term declines in values of their investments. We determine the chances of attaining the Client's financial goals using various levels of risk in their portfolio. Generally, the more sensitive a Client is to short-term drops in value, the less risk a Client will seek to take with their portfolios. However, the client must balance risk aversion with their desire to attain their long-term goals. We will use these factors to make our recommendations. Depending on the outcome of our evaluation of the Client's sensitivity to risk and the probability of attaining the financial goals with a beginning portfolio value, we will recommend one of the following portfolio asset allocations: 1. Ultra-Aggressive 2. Aggressive 3. Moderate-Aggressive 4. Moderate 5. Moderate-Conservative 6. Conservative 7. Defensive-Conservative 8. Ultra-Conservative 9. Cash 10% fixed income, 90% equity, 20% fixed income, 80% equity, 30% fixed income, 70% equity, 40% fixed income, 60% equity, 50% fixed income, 50% equity, 60% fixed income, 40% equity, 70% fixed income, 30% equity, 80% fixed income, 20% equity or 100% cash and short-term fixed income. These asset allocations are broken up further into asset class segments such as large company equity, mid-size company equity, small size company equity and international equity. The percentages of each segment will vary slightly between portfolios due to Client preferences. The percentages of the actual portfolio allocation and the recommended allocation can vary as much as 5% before being considered out of balance. If the actual portfolio allocation is out of balance, we will recommend changes that will bring the portfolio into balance. However, asset classes may vary by more than 5% from target allocation during temporary time periods. We review the portfolio allocation at the end of each calendar quarter. C. Client Account Management After the initial meeting, but prior to engaging Crossgate to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:  Asset Allocation – Crossgate will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.  Portfolio Construction – Crossgate will develop a portfolio for the Client that is intended to meet the  stated goals and objectives of the Client. Investment Management and Supervision – Crossgate will provide investment management and ongoing oversight of the Client’s investment portfolio. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by the client, Crossgate will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. Crossgate will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, stand-alone planning engagements per the terms and conditions of a separate Financial Planning and Consulting Agreement, etc., for which Crossgate may charge a separate or additional fee). Please Note. Crossgate believes that it is important for the client to address financial planning issues on an ongoing basis. Crossgate’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Crossgate. Please Also Note: Crossgate does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Crossgate does not prepare legal documents, prepare tax returns, or sell Page 7 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Crossgate and/or its representatives. If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Crossgate, shall be responsible for the quality and competency of the services provided. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Crossgate recommends that a client roll over their retirement plan assets into an account to be managed by Crossgate, such a recommendation creates a conflict of interest if Crossgate will earn new (or increase its current) compensation as a result of the rollover. If Crossgate provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Crossgate is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Crossgate, whether it is from an employer’s plan or an existing IRA. Crossgate’s Chief Compliance Officer, John Rea, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Crossgate generally recommends that Fidelity Brokerage Services, LLC and National Financial Services, LLC (collectively “Fidelity”) serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Fidelity charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Fidelity, do not currently charge fees on individual equity or ETF transactions, others do). Please Note: there can be no assurance that Fidelity will not change its transaction fee pricing in the future Please Also Note: Fidelity may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. These fees/charges are in addition to Crossgate’s investment advisory fee at Item 5 below. Crossgate does not receive any portion of these fees/charges. ANY QUESTIONS: Crossgate’s Chief Compliance Officer, John D. Rea, remains available to address any questions that a client or prospective client may have regarding the above. Non-Discretionary Service Limitations. Clients that determine to engage Crossgate on a non- discretionary investment advisory basis must be willing to accept that Crossgate cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, Crossgate will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Portfolio Activity. Crossgate has a fiduciary duty to provide services consistent with the client’s best interest. Crossgate will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s Page 8 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  investment objective. Based upon these factors, there may be extended periods of time when Crossgate determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Please Note-Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by Crossgate independent of engaging Crossgate as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Crossgate’s initial and ongoing investment advisory services. In addition to Crossgate’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Cash Positions. Crossgate continues to treat cash as an asset class. As such, unless determined to the contrary by Crossgate, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Crossgate’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Crossgate may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Crossgate’s advisory fee could exceed the interest paid by the client’s money market fund. Variable Annuity Sub-divisions. Crossgate may also render discretionary investment management services to clients relative to variable annuity products that they may own. In so doing, Crossgate directs the allocation of client assets among the various mutual fund sub-divisions which comprise the variable annuity product based upon the investment objectives of the client. Cybersecurity Risk. The information technology systems and networks that Crossgate and its third-party service providers use to provide services to Crossgate’s clients employ various controls that are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Crossgate’s operations and/or result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Crossgate are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although Crossgate has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Crossgate does not control the cybersecurity measures and policies employed by third-party service providers, issuers of securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges and other financial market operators and providers. Client Privacy and Confidentiality. Crossgate maintains policies and procedures designed to help protect the confidentiality and security of client nonpublic personal information (“NPPI”). NPPI includes, but is not limited to, social security numbers, credit or debit card numbers, state identification card numbers, driver’s license number and account numbers. Crossgate maintains administrative, technical, and physical safeguards designed to protect such information from unauthorized access, use, loss, or destruction. These safeguards include controls relating to data access, information security, and incident response, and are reviewed to address changes in risk and business. Client information may be disclosed in response to regulatory requests, legal obligations, or as otherwise permitted by law, and any such disclosure is made in accordance with applicable privacy and confidentiality requirements. Crossgate may engage non-affiliated service providers in connection with providing advisory services, and such providers may have access to client NPPI, as necessary, to perform their functions. These service providers represent to Crossgate that they maintain safeguards designed to protect client information from Page 9 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  unauthorized access or use and that they will provide notice to Crossgate in the event of a cybersecurity incident involving client information. While Crossgate maintains policies and procedures designed to protect client information, such measures cannot eliminate all risk. Upon becoming aware of a data breach involving a client’s NPPI, Crossgate will notify clients of such breach as may be required by applicable state and federal laws. Artificial Intelligence. Crossgate may use certain Artificial Intelligence (“AI”) tools in connection with its investment advisory services. Crossgate has adopted an AI Policy that governs the appropriate use of AI tools to ensure that Crossgate and its employees abide by their fiduciary duty and comply with all applicable regulations. AI tools are not used by Crossgate as a substitute for professional judgment by Crossgate or its employees, and all AI generated output is reviewed by Crossgate for accuracy. All investment decisions and recommendations are made and approved by Crossgate. The use of AI tools does not guarantee the accuracy of analyses or the success of any investment strategy. Clients should not assume that reliance on AI tools results in better performance or reduces risk. AI tools involve limitations and risks that Crossgate monitors and manages. These risks include, but are not limited to, data security concerns, potential inaccuracies, and possible algorithmic biases. To mitigate these risks, Crossgate has implemented controls such as pre-approval requirements for AI tools, restrictions on providing nonpublic personal information to public AI systems, vendor due diligence, review of AI-generated materials, and employee training on appropriate AI usage. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Crossgate shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Crossgate reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within Crossgate’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of Crossgate’s unmanaged accounts. Please Note: Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG). ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Crossgate), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Crossgate does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. Page 10 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Reporting Services. Crossgate can also provide, account reporting services, which can incorporate client investment assets that are not part of the assets that Crossgate manages (the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or his/her/its other advisors that maintain trading authority, and not Crossgate, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, in writing, Crossgate does not provide investment management, monitoring or implementation services for the Excluded Assets. The sole exception to the above shall be if Crossgate is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. If Crossgate is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Crossgate shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client can engage Crossgate to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Crossgate and the client. eMoney (FinHub). In the event that Crossgate provides the client with access to an unaffiliated vendor’s website such as eMoney (FinHub), and the site provides access to information and/or concepts, including financial planning, the client should not, in any manner whatsoever, infer that such access is a substitute for services provided by Crossgate. Rather, if the client utilizes any such content, the client does so separate and independent of Crossgate. Trustee Directed Plans. Crossgate can be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Crossgate will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Crossgate will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. Client Retirement Plan Assets. If requested to do so, Crossgate can provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, Crossgate shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Crossgate’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. Crossgate will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Crossgate of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by Crossgate to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of Crossgate calculating its advisory fee. Client Obligations. In performing our services, Crossgate shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Crossgate if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Crossgate) will be profitable or equal any specific performance level(s). D. Wrap Fee Programs Crossgate does not manage or place Client assets into a wrap fee program. Investment advisory services are provided directly by Crossgate. Page 11 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  E. Assets Under Management As of December 31, 2025, Crossgate manages $271,873,742 in Client assets, $269,436,540 of which are managed on a discretionary basis and $2,437,202on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client shall sign one or more agreements that detail the responsibilities of Crossgate and the Client. A. Fees for Advisory Services Financial Planning Services-Stand-Alone engagement Financial plans are based on an hourly rate of $250 per hour. After the initial meeting with the Client, we will present a financial planning agreement which states the hourly fee and a maximum total cost of the service based upon the number of hours we expect to spend on the services listed in the agreement. The Client will not be billed more than the maximum amount stated in the agreement even if we spend more hours than we estimated. The maximum fee will include a meeting with the Client to present a written financial plan. If the Client requests additional services be performed after the presentation of the financial plan, the Client will be informed that there will be additional charges at $250 per hour. These activities may include helping the Client implement some or all of the recommendations, creating additional scenarios for retirement projections or answering new questions posed by the Client. The average financial plan takes about ten hours to complete but may take more time if the situation is more complicated. Therefore, financial plans can cost the Client from $2,500 to $5,000 depending on the complexity of the Client's financial situation. The hourly rate is not negotiable. That would change the maximum cost of the financial planning engagement for the Client as well as the scope of the engagement. Investment Advisory Services Investment advisory fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the following schedule: Assets Under Management ($) First $1,000,000 Next $1,000,000 Next $1,000,000 Next $1,000,000 Next $1,000,000 Over $5,000,000 Annual Rate (%) 1.00% 0.75% 0.50% 0.40% 0.30% 0.20% Fees are negotiable at the sole discretion of the Advisor. The Investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Crossgate will be independently valued by the Custodian. Crossgate will conduct periodic reviews of the Custodian’s valuations. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Page 12 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Fee Dispersion. Crossgate, in its discretion, may charge a lesser investment advisory fee, charge a flat fee, waive its fee entirely, or charge fees on a different interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, family members, courtesy accounts, competition, grandfathered fee schedules, employees and negotiations with client, etc.). Please Note: As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. ANY QUESTIONS: Crossgate’s Chief Compliance Officer, John D. Rea, remains available to address any questions that a client or prospective client may have regarding advisory fees. B. Fee Billing Financial Planning Services Financial planning fees are invoiced 50% upon signing of the financial planning agreement and 50% after the financial plan has been presented. Investment Management Services Investment advisory fees will be calculated by the Advisor and deducted from the Client’s account[s] at the Custodian. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Crossgate at the end of each quarter. We prefer that we deduct our Clients' fees directly from an account held at the Custodian. However, each Client may elect to pay us directly after receiving an invoice. Invoices are sent out at the end of each calendar quarter. That is when the fees are deducted from the Client's account if that is the payment method approved by the Client. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Crossgate directly from their accounts held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Crossgate, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian and executing broker-dealer, if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client accounts, but may charge for mutual funds and other types of investments. The investment advisory fee charged by Crossgate is separate and distinct from these custody and execution fees. In addition to the investment advisory fees paid to Crossgate, Clients will incur other fees. Mutual funds and ETFs have annual management fees that are deducted directly from the mutual funds’ assets. These fees can vary from 0.01% per year to over 2.00% per year depending on the fund. Mutual funds may also charge fees for balances that are below a minimum amount. Some funds charge a fee if it is sold within a certain period of time from the purchase date. Some custodians such as Vanguard and Fidelity Investments charge a small transaction fee when Clients buy specific funds. There also may be brokerage fees in connection with trades of certain types of securities such as stocks and ETFs. Additional information regarding brokerage fees can be found in Item 12 - Brokerage Practices. Crossgate does not receive any remuneration based on the purchase or sales of investments. Our practice is to recommend funds that do not charge a sales load or fee. These are called "no-load" funds. Clients always have the option to purchase investment products that we recommend through other brokers or agents that are not affiliated with Crossgate. D. Advance Payment of Fees and Termination Financial Planning Services Crossgate may be partially compensated for its financial planning services in advance of the engagement. Page 13 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. Upon termination, Crossgate will bill the Client for the number of hours spent on the engagement. The Client will receive a refund for any amount paid in excess of the amount billed. An accounting of the hours spent will be sent to the Client. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Investment Management Services Crossgate is compensated for its services at the end of the quarter in which investment advisory services are rendered. Either party may terminate an investment advisory agreement, at any time, by providing written notice to the other party. The Client will incur charges for advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Billing is conducted quarterly in arrears based upon the market value of the account on the last day of the billable quarter. Crossgate’s policy is to treat intra- quarter account additions and withdrawals equally (i.e., does not charge for intra-quarter additions or withdrawals-revise as necessary) unless indicated to the contrary on the Firm’s Investment Advisory Agreement executed by the client E. Compensation for Sales of Securities Crossgate does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Crossgate does not charge any Clients a performance-based fee for its investment advisory services. The fees charged by Crossgate are as described in “Item 5 – Fees and Compensation” above and are not based upon the capital appreciation of the funds or securities held by any Client. Crossgate does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Crossgate provides advisory services to individuals and high net-worth individuals, trusts and estates. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. We generally do not have a minimum relationship size or minimum fee requirement for new Clients. However, we would not enter into an investment advisory agreement if the amount being managed would not be economical for the Client. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Crossgate primarily employs fundamental analysis in developing investment strategies for its Clients. Research and analysis from Crossgate is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative Page 14 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As part of the fundamental analysis, we incorporate some of the concepts of Modern Portfolio Theory (MPT) in the construction of our Client's portfolios. MPT was pioneered by Harry Markowitz in his paper "Portfolio Selection" published in 1952 by the Journal of Finance. The theory contains the view that investors are risk- averse and can construct portfolios to optimize or maximize expected investment return based on a given level of market risk, emphasizing that risk is an inherent part of higher reward. In order to configure the optimal mix of asset classes for different levels of risk, the covariance between asset classes have to be measured. Covariance is the degree to which returns on two risky assets move in tandem. A positive covariance means that asset returns move together. A negative covariance means returns move inversely. We categorize each type of investment into a specific asset class. The broad asset classes are: 1. Fixed Income (includes cash and all types of bonds) (FI) 2. Large Cap Equity Growth (LG) 3. Large Cap Equity Value (LV) 4. Mid Cap Equity Growth (MG) 5. Mid Cap Equity Value (MV) 6. Small Cap Equity Growth SG) 7. Small Cap Equity Value (SV) 8. International Equity (IE) 9. Emerging Markets Equity (EM) 10. Other (includes real estate, commodities and currencies) Depending on the time horizon for the use of the funds in a portfolio, the risk tolerance of the portfolio owner and beneficiary and the amount of risk needed to achieve a financial goal, the portfolio will be classified in one of the following portfolio allocations: FI LG LV MG MV SG SV IE EM Other 1. Ultra Aggressive 10% 25% 25% 6% 6% 6% 6% 6% 10% 0% 2. Aggressive 20% 24% 24% 5% 5% 5% 5% 7% 5% 0% 3. Moderate 30% 20% 20% 5% 5% 5% 5% 6% 0% 0% Aggressive 4. Moderate 40% 18% 18% 4% 4% 5% 5% 6% 0% 0% 5. Moderate 50% 15% 15% 4% 4% 4% 4% 4% 0% 0% Conservative 6. Conservative 60% 12% 12% 3% 3% 3% 3% 4% 0% 0% 7. Defensive 70% 10% 10% 0% 0% 4% 4% 2% 0% 0% Conservative 8. Ultra Conservative 80% 6% 6% 0% 0% 3% 3% 2% 0% 0% 9. Cash 100% Each allocation may deviate from the percentage listed above by plus or minus five percent before the portfolio is considered unbalanced. If any of the percentages are more than five percent above or below the percentages listed in the table above, we will make recommendations to rebalance the portfolio. Rebalancing means that investments are sold in asset classes that are above the target percentage and then investments are purchased in asset classes that are under the target percentage. Page 15 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Investment Decision Criteria Most often we recommend open-ended mutual funds and in a few cases ETFs to create or change a portfolio of investments. A mutual fund is a pool of funds collected from many investors for the purpose of investing in securities. By pooling together funds from many investors, an investor benefits by having access to professional investment managers and immediate diversification. Open-ended mutual funds have shares that are sold directly to investors. The number of shares expand and contract depending on the demand for the fund. The fund will buy the shares back from the investor providing liquidity. A majority of mutual funds are open-ended. An ETF is a security that tracks an index, commodity or a basket of assets like an index fund but trades like a stock on an exchange. ETFs can be traded throughout the day whereas open-ended mutual funds are exchanged only at the end of each trading day. We review and monitor appropriate parameters for the mutual funds and ETFs we recommend. The parameters we use are: 1. Consistency of performance. Mutual funds are identified that have experienced consistent above average performance with respect to their category peers. Crossgate identifies for further analysis those funds that have been ranked in the top 50 percentile of their category for the last three-year and five-year periods. 2. Persistency of Style. One of the basic tenants of modern portfolio theory is to develop a portfolio using securities that are consistent in their investment style throughout the holding period. This portion of the analysis finds those mutual funds by reviewing their investment style history. The analysis also reviews consistency in rolling period returns and in bond quality ratings for fixed income instruments. 3. Risk-Adjusted Performance Data. During this portion of the analysis, we look at past reviews and commentaries by analysts in various publications, portfolio composition versus peers, sector weightings, regional exposures, risk and return profiles and risk adjusted rates of returns. Standard Deviation, Sharpe Ratios, R-squared and Alphas are reviewed. 4. Operations. The analysis reviews the manager, and the tenure of the manager, fees and expenses, shareholder report grade and any other factors that may be appropriate for the category under analysis. Mutual fund managers must have been in place for five years or longer. The mutual funds must be available with no purchase fee (no-load) and a net asset value (NAV). Net asset value is the total value of all of the securities in the fund divided by the total number of shares outstanding. 5. Portfolio Risk. This analysis reviews portfolio risk by reviewing portfolio statistics, turnover ratio, actual fund holdings, total number of holdings and the percentage of assets in the top ten holdings. We rank the mutual funds in each category in accordance with the above formulae. The goal is to select at least two to three funds for inclusion in our approved list of funds for each category. Sometimes only one or none of the mutual funds make the grade. In those instances, appropriate index funds may be used. We also use information received from the companies that manage the mutual funds. B. Risk of Loss There is inherent risk in all types of investments although each investment has different types of risk and different degrees of risk. We define risk as the chance that an investment will lose value. One risk in using our investment strategy is having an allocation in an asset class that goes down in value in a particular time period. We do not use market timing to make portfolio changes. That means that even if the equity markets have reached an all-time high and the news media reports that the stock market looks like it will go down, we do not make changes in a portfolio allocation for that reason alone. For example, the Ultra Aggressive allocation would lose more than the Ultra Conservative allocation if stocks in the United States and around the world lose value. Page 16 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Several risks are associated with fixed income securities. One risk is interest rate risk. Bond prices fall as interest rates rise. The longer the term of the bond and the lower the interest rate, the more the bond value will fall. Another risk is market risk. The demand and supply of particular kinds of bonds will affect the value. Default risk is the risk that the bond issuer will not be able to pay the interest or principal on the bond in a timely manner. Inflation risk is the risk that the rate of price increases in the economy deteriorates the returns associated with the bond. Inflation erodes the purchasing power of the interest and principal over time. Stocks have greater overall risks because there is a higher probability of losing more value with stocks than bonds. When someone owns stock, they participate in the profits or losses of that company. There is no promise to pay the common stock shareholders a certain amount for the shares in the future. Stock values will change depending on the individual results of the company. Therefore, each stock has specific company risk. That means the value will not only change as a result of a change in earnings but also because of the perception of how management is performing and other internal issues such as fraud or criminal activity. Stock values are also influenced by industry risk. That is the risk that problems may arise as a result of an industry wide problem such as lower prices for the sales of products made or the increase in raw materials used for making the product. Commodities have price risk. Metals such as gold or silver do not produce income. Therefore, any financial return is based on the price of the commodity at any point in time. That means the price will depend on the demand and supply for that commodity. That could cause the price to fluctuate greatly and could go down in value. Crossgate recommends mutual funds for most of the investments used in a portfolio. When using a mutual fund, there is a risk that the manager may make poor decisions and purchase stocks or bonds that do not perform well. There is also a risk that the portfolio manager may be changed by the fund owner. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information the There are no legal, regulatory or disciplinary events involving Crossgate or any of its Supervised Persons. Crossgate and its Supervised Persons value the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are on Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 121856. Item 10 – Other Financial Industry Activities and Affiliations Neither Crossgate, nor its representatives, are registered or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Page 17 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  Neither Crossgate, nor its representatives, are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a representative of the foregoing. Crossgate does not receive, directly or indirectly, compensation from investment advisors that it recommends or selects for its clients. Succession Plan As a fiduciary, Crossgate Wealth Advisors, LLC has certain legal obligations, including the obligation to act in clients’ best interest. Crossgate Wealth Advisors, LLC maintains a Business Continuity and Succession Plan and seeks to avoid a disruption of service to Clients in the event of emergency or an unforeseen loss of key personnel, due to disability or death. To that end, Crossgate Wealth Advisors, LLC has devised a plan for internal succession. ANY QUESTIONS: Crossgate’s Chief Compliance Officer, John D. Rea, remains available to address any questions that a client or prospective client may have regarding Crossgate’s succession plan. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Crossgate maintains an investment policy relative to personal securities transactions. This investment policy is part of Crossgate’s overall Code of Ethics, which serves to establish a standard of business conduct for all of Crossgate’s Representatives that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request. In accordance with Section 204A of the Investment Advisers Act of 1940, Crossgate also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by Crossgate or any person associated with Crossgate. B. Neither Crossgate nor any related person of Crossgate recommends, buys, or sells for client accounts, securities in which Crossgate or any related person of Crossgate has a material financial interest. C. Crossgate and/or representatives of Crossgate may buy or sell securities that are also recommended to clients. This practice may create a situation where Crossgate and/or representatives of Crossgate are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that security for investment and then immediately sells it at a profit upon the rise in the market price which follows the recommendation) could take place if Crossgate did not have adequate policies in place to detect such activities. In addition, this requirement can help detect insider trading, “front-running” (i.e., personal trades executed prior to those of Crossgate’s clients) and other potentially abusive practices. Crossgate has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of Crossgate’s “Access Persons”. Crossgate’s securities transaction policy requires that an Access Person of Crossgate must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person’s current securities holdings or brokerage statements at least once each twelve (12) month period thereafter on a date Crossgate selects; provided, however that at any time that Crossgate has only one Access Person, he or she shall not be required to submit any securities report described above. D. Crossgate and/or representatives of Crossgate may buy or sell securities, at or around the same time as those securities are recommended to clients. This practice creates a situation where Crossgate and/or representatives of Crossgate are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. As indicated above in Item 11.C, Crossgate Page 18 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of Crossgate’s Access Persons John D. Rea and Supervised Persons of Crossgate may buy and sell open-ended mutual funds that we recommend to our Clients without prior notice to any Client. While Crossgate allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Crossgate, or any Supervised Person, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices In the event that the client requests that Crossgate recommend a broker-dealer/custodian for execution and/or custodial services, Crossgate generally recommends that investment advisory accounts be maintained Fidelity. Prior to engaging Crossgate to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with Crossgate setting forth the terms and conditions under which Crossgate shall advise on the client's assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian. Factors that Crossgate considers in recommending Fidelity (or any other broker-dealer/custodian to clients) include historical relationship with Crossgate, financial strength, reputation, execution capabilities, pricing, research, and service. Broker-dealers such as Fidelity can charge transaction fees for effecting certain securities transactions (See Item 4 above). To the extent that a transaction fee will be payable by the client to Fidelity, the transaction fee shall be in addition to Crossgate’s investment advisory fee referenced in Item 5 above. To the extent that a transaction fee is payable, Crossgate shall have a duty to obtain best execution for such transaction. However, that does not mean that the client will not pay a transaction fee that is higher than another qualified broker-dealer might charge to affect the same transaction where Crossgate determines, in good faith, that the transaction fee is reasonable. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, transaction rates, and responsiveness. Accordingly, although Crossgate will seek competitive rates, it may not necessarily obtain the lowest possible rates for client account transactions. Research and Benefits: Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Crossgate can receive from Fidelity (or another broker-dealer/custodian, investment manager, platform sponsor, mutual fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist Crossgate to better monitor and service client accounts maintained at such institutions. Included within the support services that can be obtained by Crossgate can be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support-including client events, computer hardware and/or software and/or other products used by Crossgate in furtherance of its investment advisory business operations. Crossgate’s clients do not pay more for investment transactions effected and/or assets maintained at Fidelity as the result of this arrangement. There is no corresponding commitment made by Crossgate to Fidelity, or any other any entity, to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as result of the above arrangement. Crossgate does not receive referrals from any broker-dealer. Page 19 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  ANY QUESTIONS: Crossgate’s Chief Compliance Officer, John D. Rea, remains available to address any questions that a client or prospective client may have regarding the above arrangements and the corresponding conflict of interest presented by such arrangements. Directed Brokerage. Crossgate recommends that its clients utilize the brokerage and custodial services provided by Fidelity. The Firm generally does not accept directed brokerage arrangements (but could make exceptions). A directed brokerage arrangement arises when a client requires that account transactions be affected through a specific broker-dealer/custodian, other than one generally recommended by Crossgate (i.e., Fidelity). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Firm will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by Crossgate. As a result, a client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Please Note: In the event that the client directs Crossgate to effect securities transactions for the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through Crossgate. Please Also Note: Higher transaction costs adversely impact account performance. Please Further Note: Transactions for directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. Order Aggregation. Transactions for each client account generally will be affected independently unless Firm decides to purchase or sell the same securities for several clients at approximately the same time. Firm may (but is not obligated to) combine or “bunch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Firm’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. Firm shall not receive any additional compensation or remuneration as the result of such aggregation. Crossgate’s representatives may, at times, be aggregated with client orders. Crossgate requires its representatives to submit documentation detailing the order its representatives wish to aggregate with client orders prior to executing the order. The representative’s documentation is reviewed by Crossgate’s Chief Compliance Officer and the order is either approved or denied depending on the outcome of the review. Item 13 – Review of Accounts All of our Clients' portfolios are reviewed on a quarterly basis. As part of the review, we compile a summary of each portfolio by investment. We then look at the year-to-date, one and three year returns as well as the one and three-year Morningstar category ranks for each investment. Morningstar is a company that compiles information on stocks, mutual funds and ETFs. The portfolio is also summarized by asset class and compared to the targets agreed upon with the Client. After making this review, we write a letter to each Client summarizing the findings of the review and the recommendations. If the actual asset allocation has a category or categories more or less than five percent compared to the targets, we may make a recommendation to rebalance the portfolio. Poor performance of an investment or a change in a Client's situation may also prompt us to make recommendations for change. We will review a Client's portfolio in advance of an annual or specially called meeting. Besides a quarterly review, we strive to meet with a Client at least once a year in person or by phone to review the portfolio and to discuss any possible changes in a Client's goals or tolerance for risk. Reviews are performed by John D. Rea and Nickolaus C. von Dohlen. The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage Page 20 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Crossgate Crossgate and its Supervised Persons do not receive any compensation for referring Clients nor does Crossgate compensate anyone for referring Clients to us. Participation in Institutional Advisor Platform As indicated at Item 12 above, Crossgate can receive from Fidelity (and others) without cost (and/or at a discount), support services and/or products. Crossgate’s clients do not pay more for investment transactions effected and/or assets maintained at Fidelity (or any other institution) as result of this arrangement. There is no corresponding commitment made by Crossgate to Fidelity, or to any other entity, to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as the result of the above arrangement. ANY QUESTIONS: Crossgate’s Chief Compliance Officer, John D. Rea, remains available to address any questions that a client or prospective client may have regarding the above arrangement and the corresponding conflict of interest presented by such arrangement. B. Compensation for Client Referrals Crossgate does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Crossgate to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Crossgate to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Surprise Independent Examination Crossgate is deemed to have custody over certain Client accounts and/or securities as part of their access to Client login credentials, pursuant to securities regulations the Advisor is required to engage an independent accounting firm to perform an annual surprise examination of those assets and accounts over which Crossgate maintains custody. Any related opinions issued by an independent accounting firm are filed with the SEC and are publicly available on the SEC’s Investment Adviser Public Disclosure website (http://adviserinfo.sec.gov). Item 16 – Investment Discretion The client can determine to engage Crossgate to provide investment advisory services on a discretionary basis. Prior to engaging Crossgate to provide investment management services, the client will be required Page 21 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com  to enter into a formal Investment Advisory Agreement with Crossgate setting forth the terms and conditions under which Crossgate shall manage the client's assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian. Clients who engage Crossgate on a discretionary basis may, at any time, impose restrictions, in writing, on Crossgate’s discretionary authority. (i.e., limit the types/amounts of particular securities purchased for their account, exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe Crossgate’s use of margin, etc.). Item 17 – Voting Client Securities Crossgate does not vote client proxies. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients will receive their proxies or other solicitations directly from their custodian. Clients may contact Crossgate to discuss any questions they may have with a particular solicitation. Item 18 – Financial Information A. Crossgate does not require clients pay fees more than six months in advance. B. Crossgate is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts. C. Crossgate has not been the subject of a bankruptcy petition. ANY QUESTIONS: Crossgate’s Chief Compliance Officer, John D. Rea, remains available to address any questions regarding this Part 2A. Page 22 Crossgate Wealth Advisors, LLC Phone: (215) 860-2234 Email: john@crossadvisors.com www.crossadvisors.com