Garden State Retirement Specialists, LLC

Item 1 Cover Page Garden State Retirement Specialists, LLC ADV Part 2A, Firm Brochure Dated: September 14, 2026 Contact: Anthony Scibetta, Managing Member 27 West Street, Suite 16 Wall Street Corporate Center Red Bank, New Jersey 07701 (732) 936-9641 This brochure provides information about the qualifications and business practices of Garden State Retirement Specialists, LLC. If you have any questions about the contents of this brochure, please contact us at (732) 936-9641 or ascibetta@osaicwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Garden State Retirement Specialists, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. References herein to Garden State Retirement Specialists, LLC as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training.  Item 2 Material Changes There have been no material changes made to Garden State Retirement Specialists LLC's disclosure statement since its last Annual Amendment filing on March 20, 2025. Item 3 Table of Contents Item 1 Cover Page .................................................................................................................................... 1 Item 2 Material Changes .......................................................................................................................... 2 Item 3 Table of Contents .......................................................................................................................... 2 Item 4 Advisory Business ........................................................................................................................ 3 Fees and Compensation .............................................................................................................. 11 Item 5 Performance-Based Fees and Side-by-Side Management .......................................................... 14 Item 6 Types of Clients .......................................................................................................................... 14 Item 7 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 15 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.............. 19 Item 12 Brokerage Practices .................................................................................................................... 20 Item 13 Review of Accounts .................................................................................................................... 22 Item 14 Client Referrals and Other Compensation .................................................................................. 22 Item 15 Custody ....................................................................................................................................... 22 Item 16 Investment Discretion ................................................................................................................. 23 Item 17 Voting Client Securities .............................................................................................................. 23 Item 18 Financial Information ................................................................................................................. 23 2  Item 4 Advisory Business A. Garden State Retirement Specialists, LLC (the “Registrant”) is a limited liability company originally formed on November 16, 1999, in the state of New Jersey. The Registrant became registered as an Investment Adviser Firm in February 2005 and changed its name to Garden State Retirement Specialists, LLC in November 2009. The Registrant is principally owned by Anthony Scibetta, the Registrant’s Managing Member and Chief Compliance Officer. B. INVESTMENT ADVISORY SERVICES The Registrant provides discretionary and/or non-discretionary investment advisory services on a fee basis. The Registrant’s annual investment advisory fee is generally based upon a percentage (%) of the market value of the assets placed under the Registrant’s management. Prior to engaging the Registrant to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Registrant 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. The Registrant provides investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets primarily among various wealth programs consistent with the designated investment objective(s). WEALTH PROGRAMS VISION2020 Wealth Management Platform – Advisor Managed Portfolios Program The Wealth Management Platform – Advisor Managed Portfolios Program (“Advisor Managed Portfolios”) provides comprehensive investment management of client assets through the application of asset allocation planning software as well as the provision of execution, clearing and custodial services through Pershing, LLC (“Pershing”). Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting, fund profiling and performance data, and portfolio optimization and re-balancing tools. Utilizing these tools, and based on client responses to a risk tolerance questionnaire (“Questionnaire”) and discussions that the Registrant has together with the client regarding, among other things, investment objective, risk tolerance, investment time horizon, account restrictions, and overall financial situation, the Registrant constructs a portfolio of investments for the client. This portfolio may consist of mutual funds, exchange traded funds, equities, options, debt securities, variable life, variable annuity sub-accounts (certain restrictions may apply) and other investments. Each portfolio is designed to meet the client’s individual needs, stated goals and objectives. Additionally, the client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. For further Advisor Managed Portfolios details, please see the Advisor Managed Portfolios Wrap Fee Program Brochure. We provide this brochure to you prior to or concurrent with your enrollment in Advisor Managed Portfolios. Please read it thoroughly before investing. 3  VISION2020 Wealth Management Platform – Model Portfolio Strategists Program The Wealth Management Platform - Model Portfolio Strategies Program (“Model Program”) is offered as a discretionary Wrap Account program which bundles advisory and administrative fees, as well as transaction charges into one asset-based fee. The Model Program offers Model Program Clients managed asset allocation models (“Asset Allocation Models”) of mutual funds or exchange traded funds (“ETFs”) diversified across various investment styles and strategies. The Asset Allocation Models are constructed by managers as set forth in the VISION2020 Wealth Management Platform – Model Portfolios Program Part 2A – Appendix 1 (“Program Managers”). Program Managers that recommend mutual fund Asset Allocation Models use load waived or no-load mutual funds. The cost of purchasing and holding mutual fund shares through the Model Program may be more or less than investing in mutual fund shares in a brokerage account, depending upon the amount of the advisory fees and the specific mutual funds selected for investment within the Model Program. Based upon the risk tolerance of each Client, the Model Program utilizes a system that selects a specific Asset Allocation Model which may contain either 1) a combination of mutual funds or 2) a combination of exchange traded funds (“ETFs”). Whether mutual funds or exchange traded funds are used will depend on which Model Program Manager is used. Registrant and Client will select an Asset Allocation Model. After such determination is made, Registrant, with the assistance of program sponsor, VISION2020 Wealth Management Corp. (“Program Sponsor”), will open a Model Program account and client assets will be invested in the specific investments contained within the recommended Asset Allocation Model. The Model Program will be governed by an advisory client agreement signed between Client, Registrant, as Advisor and Program Sponsor as Co-Advisor. With the Client’s assistance, Registrant will determine initial and ongoing suitability of the Model Program selected. As Co-Advisor, Program Sponsor will provide monitoring and review of Asset Allocation Models. Program Sponsor has the discretion to modify and/or rebalance a Model Program Manager’s Asset Allocation Model and its associated Model Program client accounts without Client consent consistent with the Client’s agreed upon investment objectives and risk tolerance. VISION2020 Wealth Management Platform – SMA and UMA Account Program The Wealth Management Platform – SMA and UMA Account Program (“Wealth Managed Account Program” or “WMAP”) provides suitable Clients the opportunity to invest their assets across multiple investment strategies and asset classes by implementing an asset allocation strategy. Sponsored by VISION2020 Wealth Management Corp. (“Program Sponsor”), WMAP is a Wrap Account program that offers these advisory services along with brokerage and custodial services for a single, annual, asset-based advisory fee. Registrant will present the Client with a WMAP asset allocation model (“WMAP Model”) for Client approval which will consist of: 1) third party money managers (“WMAP Managers”) who will manage Client funds according to a particular equity or fixed income model or strategy, or 2) no-load mutual funds (“Funds”), or 3) exchange traded funds (“ETFs”) or any combination thereof (individually or collectively, “WMAP Investments”). WMAP Investments will be managed according to the selected WMAP Model. WMAP 4  Models consist of a separately managed account or a series of separately managed accounts (collectively, “SMA Account”) or a unified managed account (“UMA Account”) as further described below. A WMAP Model will be suggested to the Client based upon Client responses to a risk tolerance questionnaire (“Questionnaire”) and/or discussion between Registrant and Client regarding among other things, investment objective, risk tolerance, investment time horizon, account restrictions, and overall financial situation. WMAP clients enter into an advisory client agreement (“Client Agreement”) with Registrant as Advisor, and Program Sponsor as Co-Advisor. Registrant will monitor the Client’s WMAP Investments on an ongoing basis. Registrant and Client will be responsible for determining initial and ongoing suitability. Program Sponsor has entered into a sub-agreement with Envestnet Asset Management, Inc. (“Envestnet”) pursuant to which Envestnet will perform due diligence and provide research on WMAP Managers, construct and recommend asset allocation targets to be used in WMAP Models and provide a password-protected web site and associated technology to assist the Advisor and Client with the selection and adjustment of WMAP Models. Additional Program Sponsor services are disclosed in the Client Agreement. SMA Account: An SMA Account may contain one or multiple WMAP Managers with each WMAP Manager investing according to a specific model or strategy and each in their own custodial account. The SMA Model may also contain Funds, generally used to compliment the WMAP Managers employed within the SMA Model and when the recommended allocation to an asset class is too small for a WMAP Manager to manage. After discussion with the Client and after the relevant information is processed, WMAP provides an asset allocation model which consists of asset allocation targets or sleeves across various asset classes and investment strategies. The Advisor and the Client complete the SMA Account by choosing which WMAP Managers and Funds will be contained within each asset allocation sleeve. Upon suitability determinations made by the Advisor and Client, Advisor may adjust the aforementioned asset allocation targets, within predetermined limits. UMA Account: A UMA Account may contain one or multiple WMAP Managers with each WMAP Manager investing according to a specific model or strategy. The UMA Account may also contain Funds and ETFs. Unlike the SMA Account, all WMAP Manager investments, Funds and ETFs will be held in a single custodial account. Overlay management is provided to coordinate the trading activities of UMA Account Managers, rebalancing and to provide greater tax-efficiency. After discussion with the Client and after the relevant information is processed, WMAP provides an asset allocation model which consists of asset allocation targets or sleeves across various asset classes and investment strategies. The Advisor and the Client complete the UMA Account by choosing which Third Party Managers, Funds and ETFs will be contained within each asset allocation sleeve. Upon suitability determinations made by the Advisor and Client, Advisor may adjust the aforementioned asset allocation targets or create its own asset allocation model within predetermined limits. 5  Genesis Series: The Genesis Series is made up of three separate investment strategies: PMC Passive Foundation, PMC American Funds Active Core and PMC Strategies EFT. Each investment strategy has a different account profile and minimum account requirement. The following is a brief description of each strategy: PMC Passive Foundation – The PMC Passive Foundation strategy is made up of seven discretionary, strategically managed portfolios across the risk spectrum and is constructed of 4-8 passive index mutual funds. The strategy is invested solely in mutual funds and requires an account minimum of $5,500. PMC American Funds Active Core – The PMC American Funds Active Core strategy is made of up seven discretionary, strategically managed portfolios constructed around the philosophy of selecting a core group of active managers to achieve potentially superior long-term results. This strategy is solely invested in American Fund mutual funds and requires an account minimum of $10,000. PMC Strategic ETF – The PMC Strategic ETF strategy is made up of seven discretionary, strategically managed portfolios constructed using only long-term ETFs. Portfolios span the investor risk/return spectrum, from capital preservation to aggressive. This strategy is solely invested in ETFs and requires an account minimum of $15,000. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) The Registrant may provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes, including the Registrant’s representatives in their individual capacities as registered representatives of a broker-dealer and/or licensed insurance agents. (See disclosures at Item 10 C.) The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the quality and competency of the services provided. It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Registrant’s previous recommendations and/or services. 6  MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Registrant may provide financial planning and related consulting services. Neither the Registrant nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. The Registrant does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with the Registrant, if desired. Furthermore, although the Registrant may provide recommendations regarding non- investment related matters, such as estate planning, tax planning and insurance, the Registrant does not serve as a law firm, accounting firm, or insurance agency, and no portion of Registrant’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, the Registrant does not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a client, Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.), including representatives of Registrant in their separate individual capacities as representatives of Osaic Wealth, Inc. (“Osaic”), an SEC registered and FINRA member broker-dealer and as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the quality and competency of the services provided. Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a non-discretionary investment advisory basis must be willing to accept that Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Therefore, in the event that Registrant would like to make a transaction for a client’s account (including an individual holding or in the event of general market correction), and the client is unavailable, Registrant will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. 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 Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. If Registrant provides a recommendation as to 7  whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Registrant 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 Registrant, whether it is from an employer’s plan or an existing IRA. 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 Registrant independent of engaging Registrant as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Registrant’s initial and ongoing investment advisory services. DFA Mutual Funds. Registrant utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers. Therefore, if the client was to terminate Registrant’s services, and not transition to another adviser who utilizes DFA funds, restrictions regarding additional purchases of, or reallocation among other, DFA funds will generally apply. Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Registrant 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, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. 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 Registrant 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 Registrant 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. The above does not apply to the cash component maintained within a Registrant 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. 8  The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Registrant unmanaged accounts. Cash Positions. Registrant continues to treat cash as an asset class. As such, unless determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Registrant’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), Registrant 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, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. Cybersecurity Risk. The information technology systems and networks that Registrant and its third-party service providers use to provide services to Registrant’s clients employ various controls that are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and/or result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although the Registrant has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that the Registrant 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. The Registrant 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. The Registrant 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. The Registrant 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. The Registrant confirms that service providers maintain safeguards designed to protect client information from unauthorized access or use and provide notice to the Registrant in the event of a cybersecurity incident involving client information maintained by the service provider. While the Registrant maintains policies and procedures designed to protect client information, such measures cannot eliminate all risk. The Registrant will notify clients in the event of a data breach involving their NPPI as may be required by applicable state and federal laws. 9  Bitcoin, Cryptocurrency, and Digital Assets. For clients who want exposure to Bitcoin, cryptocurrencies, or digital assets, the Registrant will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Bitcoin and cryptocurrencies are digital assets that can be used for various purposes, including transactions, decentralized applications, and speculative investments. Most digital assets use blockchain technology, an advanced cryptographic digital ledger to secure transactions and validate asset ownership. Unlike conventional currencies issued and regulated by monetary authorities, cryptocurrencies generally operate without centralized control, and their value is determined by market supply and demand. While regulatory oversight of digital assets has evolved significantly since their inception, they remain subject to variable regulatory treatment globally, which may impact their risk profile and liquidity. Given that cryptocurrency investments are speculative and subject to extreme price volatility, liquidity constraints, and the potential for total loss of principal, the Registrant does not exercise discretionary authority to purchase cryptocurrency investments for client accounts. Any investment in cryptocurrencies must be expressly authorized by the client. The Registrant does not recommend or advocate for the purchase of, or investment in, Bitcoin, cryptocurrencies, or digital assets. Such investments are considered speculative and carry significant risk. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility, regulatory risk, technological risk, security and custody risk, and complete loss of principal. Client Obligations. In performing its services, Registrant 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, each client is advised that it remains their responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Registrant’s previous recommendations and/or services. Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2 of Form ADV as well as Form CRS shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. to providing investment advisory services, an C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. Registrant does not sponsor a wrap fee program for its investment advisory services. However, Registrant is a participating investment adviser in certain unaffiliated wrap and managed account fee programs. The programs the Registrant may recommend are sponsored by VISION2020 Wealth Management Corp. With respect to the wrap-fee and managed account programs in which Registrant is a participating investment adviser, clients pay their fees directly to the sponsoring brokers who, in turn, remit a portion of those fees to Registrant. The advisory fees remitted to Registrant are based upon an annual 10  percentage of assets under VISION2020 Wealth Management Corp.’s management, and are calculated by the sponsoring brokers either on a quarterly basis or a monthly basis. (Wrap/Separate Managed Account programs): Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately. In the event that Registrant is engaged to provide investment advisory services as part of an unaffiliated managed account program, Registrant will likewise be unable to negotiate commissions and/or transaction costs and/or seek better execution. E. As of December 31, 2025, the Registrant had $86,397,800 in assets under management on a discretionary basis and $22,910,443 in assets under management on a non-discretionary basis. Item 5 Fees and Compensation A. INVESTMENT ADVISORY SERVICES The Registrant provides discretionary and/or non-discretionary investment advisory services on a fee basis, the Registrant’s annual investment advisory fee shall be based upon a percentage (%) of the market value and type of assets placed under the Registrant’s management, generally as stated below. WEALTH PROGRAMS VISION2020 Wealth Management Platform – Advisor Managed Portfolios Program We offer Advisor Managed Portfolios as either Wrap or Non-Wrap Accounts. Wrap accounts will not incur separate transaction fees, as a single fee shall be paid by the client for all advisory services and transactions. Non-Wrap Accounts, conversely, will incur separate advisory fees and transaction charges. As such, in addition to the quarterly account fee described below for advisory services, Non-Wrap Account clients will also pay separate per-trade transaction charges. Clients selecting Advisor Managed Portfolios will pay a quarterly account fee, in advance, based upon the market value of the assets held in your account as of the last business day of the preceding calendar quarter. Advisor Managed Portfolio account fees are negotiable and will be debited from your account by our custodian. Clients will receive a full account fee refund in the event of termination within five business days of execution of the Agreement. If you terminate after the first five days, the account fee will be credited back to you on a pro-rata basis for the unused portion of the quarter. Additional, ancillary fees may apply. Please see the Advisor Managed Portfolios Wrap Fee Program Brochure for further details. 11  Our Advisor Managed Portfolios account fee schedule is generally as follows: Wrap Account: Assets Under Management $0 - $499,999 $500,000 - $999,999 $1,000,000 - $2,499,999 $2,500,000 and Up Annual Fee 2.20% 1.75% 1.50% 1.25% Non-Wrap Account: Assets Under Management $0 - $499,999 $500,000 - $999,999 $1,000,000 - $2,499,999 $2,500,000 and Up Annual Fee 1.95% 1.50% 1.25% 1.00% * The Registrant’s investment advisory fee is negotiable at Registrant’s discretion. As a result of these factors, similarly situated clients could pay different fees, the services to be provided by the Registrant to any particular client could be available from other advisers at lower fees, and certain clients may have fees different than those specifically set forth above. VISION2020 Wealth Management Platform – Model Portfolio Strategists Program Clients selecting the Model Program are charged quarterly fees based upon the assets under management. Fees are negotiable and range up to 2.50% (annualized) of the assets under management that may be collected by Advisor, its associated broker-dealer and all associated broker-dealer affiliates. VISION2020 Wealth Management Platform – SMA and UMA Account Programs Clients generally pay a single WMAP fee typically ranging from 0.85% to 2.75% for the SMA Account and 0.95% to 2.65% for the UMA Account of the value of assets in the Account, subject to negotiation. The above fees may be negotiable between the Client and the Registrant based on account size, complexity, prior relationships and related account holdings. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) The Registrant may be engaged to provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone fee basis. Registrant’s planning and consulting fees are negotiable, but generally range from $500 to $5,000 on a fixed fee basis, and $400 on an hourly rate basis, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial account. Both Registrant's Investment Advisory Agreement and the custodial/clearing agreement may authorize the custodian to debit the account for the amount of the Registrant's investment advisory fee and to directly remit that management fee to the Registrant in compliance with regulatory procedures. In the limited event that the Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice. The Registrant shall deduct fees and/or bill clients quarterly in advance, based upon the market value of the assets on the last business day of the previous quarter. 12  C. As discussed below, unless the client directs otherwise or an individual client’s circumstances require, the Registrant shall generally recommend that Pershing, LLC (“Pershing”) serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Pershing 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 Pershing, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. There can be no assurance that Pershing will not change their transaction fee pricing in the future. Pershing may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Clients may incur additional fees and expenses by the broker-dealer/custodian in connection with account transfers, account terminations, and transactions involving foreign securities or investments. These fees are separate from and in addition to the advisory fees described in Item 5.A. D. Registrant's annual investment advisory fee shall be prorated and paid quarterly, in advance, based upon the market value of the assets on the last business day of the previous quarter. The Registrant monitors client accounts for inflows and outflows during each billing period and makes prorated adjustments to the following billing period’s fee accordingly. The Investment Advisory Agreement between the Registrant and the client will continue in effect until terminated by either party by written notice in accordance with the terms of the Investment Advisory Agreement. Upon termination, the Registrant shall refund the pro- rated portion of the advanced advisory fee paid based upon the number of days remaining in the billing quarter. their E. Securities Commission Transactions. In the event that the client desires, the client can engage Registrant’s representatives, in individual capacities, as registered representatives of Osaic to implement investment recommendations on a commission basis. In the event the client chooses to purchase investment products through Osaic, Osaic will charge brokerage commissions to effect securities transactions, a portion of which Osaic shall pay to Registrant’s representatives, as applicable. The brokerage commissions charged by Osaic may be higher or lower than those charged by other broker-dealers. In addition, Osaic, relative to commission mutual fund purchases, may also receive additional ongoing 12b-1 trailing commission compensation directly from the mutual fund company during the period that the client maintains the mutual fund investment. With certain of Registrant’s representatives, Osaic has established forgivable and repayable loans, which constitute additional economic benefits (“Forgivable Loans”) for such individuals. The terms of the Osaic Forgivable Loans require that each applicable recipient remains affiliated with Osaic for a specified period of time in order to qualify for loan forgiveness. The Forgivable Loans incentivize such representatives to remain affiliated with Osaic in their separate and individual capacities as registered representatives. 13  The receipt of Forgivable Loans therefore presents conflicts of interest, because Registrant’s representatives are incentivized to recommend that clients utilize Osaic for brokerage and custodial services in order to meet the production requirements necessary for loan forgiveness, rather than basing such recommendations on a client’s particular needs. Without limiting the foregoing, the Forgivable Loans incentivize the Registrant and its representatives to recommend that existing clients keep their assets custodied at Osaic, that existing clients execute commission transactions through Osaic, and also that new clients move their assets to Osaic for receipt of such custodial and brokerage services. Clients are therefore reminded that they are not under any obligation to purchase securities commission products through Osaic and/or Registrant’s representatives, and that they may purchase such securities commission products through other, non-affiliated broker-dealers. 1. Conflict of Interest: The recommendation that a client purchase a commission product from Osaic presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any commission products from Registrant’s representatives. 2. Clients may purchase investment products recommended by Registrant through other, non-affiliated broker dealers or agents. 3. The Registrant does not receive more than 50% of its revenue from advisory clients as a result of commissions or other compensation for the sale of investment products the Registrant recommends to its clients. 4. When Registrant’s representatives sell an investment product on a commission basis, the Registrant does not charge an advisory fee in addition to the commissions paid by the client for such product. When providing services on an advisory fee basis, the Registrant’s representatives do not also receive commission compensation for such advisory services. However, a client may engage the Registrant to provide investment management services on an advisory fee basis and separate from such advisory services purchase an investment product from Registrant’s representatives on a separate commission basis. Item 6 Performance-Based Fees and Side-by-Side Management Neither the Registrant nor any supervised person of the Registrant accepts performance- based fees. Item 7 Types of Clients The Registrant’s clients shall generally include individuals, business entities, trusts, estates and charitable organizations. The Model Program account minimum is set forth in the VISION2020 Wealth Management Platform – Model Portfolios Program Part 2A – Appendix 1. The Registrant, in its sole discretion, may reduce its investment management fee (i.e., anticipated future earning capacity, anticipated future additional assets, dollar 14  amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. The Registrant may utilize the following methods of security analysis:  Fundamental - (analysis performed on historical and present data, with the goal of making financial forecasts)  Cyclical – (analysis performed on historical relationships between price and market trends, to forecast the direction of prices) The Registrant may utilize the following investment strategies when implementing investment advice given to clients:  Long Term Purchases (securities held at least a year)  Short Term Purchases (securities sold within a year) Investment Risk. Investing in securities involves risk of loss that clients should be prepared to bear. 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 the Registrant) will be profitable or equal any specific performance level(s). All investment strategies have certain risks that are borne by the investor. Although there is no way to list all risks involved with investing, the following are common risks born by the majority of investors: Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, bond prices generally fall. Market Risk: Asset prices may drop in reaction to certain unforeseen events. Also referred to as exogenous risk, this type of risk is caused by external factors independent of a security’s particular underlying fundamentals or intrinsic value. For example, geo-political, economic, legislative, and/or societal events may amplify market risk. Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. Some industries and/or companies may have historically demonstrated more stability than others. Economic factors and business functions are constantly changing. Past results are no guarantee of future performance. 15  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. Financial Risk: Also referred to as leverage risk. Excessive borrowing to finance a business’ operations may lead to financial strain and the ability to generate profits or meet certain obligations. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Counterparty Risk: The risk that each party may not be able to meet its contractual obligations. This may also be referred to as default risk for fixed income investments. In rare circumstances, the underlying securities within registered investment products may become illiquid which may restrict the ability of investors to redeem shares at quoted prices. Execution Risk: The risk that buy/sell transactions may not be executed at favorable prices. This may occur during periods of abnormal market conditions. B. The Registrant’s methods of analysis and investment strategies do not present any significant or unusual risks. However, every method of analysis has its own inherent risks. To perform an accurate market analysis the Registrant must have access to current/new market information. The Registrant has no control over the dissemination rate of market information; therefore, unbeknownst to the Registrant, certain analyses may be compiled with outdated market information, severely limiting the value of the Registrant’s analysis. Furthermore, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that a forecasted change in market value will materialize into actionable and/or profitable investment opportunities. The Registrant’s primary investment strategies - Long Term Purchases and Short Term Purchases - are fundamental investment strategies. However, every investment strategy has its own inherent risks and limitations. For example, longer term investment strategies require a longer investment time period to allow for the strategy to potentially develop. Shorter term investment strategies require a shorter investment time period to potentially develop but, as a result of more frequent trading, may incur higher transactional costs when compared to a longer term investment strategy. C. Currently, the Registrant primarily allocates client investment assets among various wealth programs on a discretionary or non-discretionary basis in accordance with the client’s designated investment objective(s). In addition, the Registrant may allocate client investment assets among various debt (bonds) and fixed income securities, mutual funds, individual securities, ETFs, and/or independent managers on a discretionary and/or non- discretionary basis in accordance with the client’s designated investment objective(s). Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:  Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,  Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges investment assets held at the account custodian as collateral. 16  These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Registrant does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). Registrant does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Registrant:  by taking the loan rather than liquidating assets in the client’s account, Registrant   continues to earn a fee on such Account assets; and, if the client invests any portion of the loan proceeds in an account to be managed by Registrant, Registrant will receive an advisory fee on the invested amount; and, if Registrant’s advisory fee is based upon the higher margined account value, Registrant will earn a correspondingly higher advisory fee. This could provide Registrant with a disincentive to encourage the client to discontinue the use of margin. The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Item 9 Disciplinary Information The Registrant has not been the subject of any disciplinary actions. Item 10 Other Financial Industry Activities and Affiliations A. As disclosed above in Item 5.E, certain of Registrant’s representatives are registered representatives of Osaic, a FINRA member broker-dealer. B. Neither the Registrant, 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. C. Broker Dealer. As disclosed above in Item 5.E, certain of Registrant’s representatives are registered representatives of Osaic, a FINRA member broker-dealer. Clients can choose to engage Registrant’s representatives, in their individual capacities, to effect securities brokerage transactions on a commission basis. Conflicts of Interest. As discussed in Items 5.E. above, certain of Registrant’s representatives have received forgivable and repayable loans (the “Forgivable Loans”). All Forgivable Loans have been provided by Osaic to certain of Registrant’s representatives. The terms and conditions of the Forgivable Loans allow the recipients to use the Forgivable Loan proceeds as they wish, but also require that each recipient remains affiliated with Osaic for a specified period of time in order to qualify for loan forgiveness. 17  The Forgivable Loans incentivize such representatives to remain affiliated with Osaic in their separate and individual capacities as registered representatives. The receipt of Forgivable Loans therefore presents conflicts of interest, as Registrant’s representatives are incentivized to recommend that clients utilize Osaic for brokerage and custodial services in order to meet the production requirements necessary for loan forgiveness, rather than basing such recommendations on a client’s particular needs. Without limiting the foregoing, the Forgivable Loans incentivize certain of Registrant’s representatives to recommend that existing clients keep their assets custodied at Osaic, that existing clients execute commission transactions through Osaic, and also that new clients move their assets to Osaic for receipt of such custodial and brokerage services. Clients are therefore reminded that they are not under any obligation to purchase securities commission products through Osaic and/or Registrant’s representatives, and that they may purchase such securities commission products through other, non-affiliated broker-dealers. Clients are also reminded that they are not required to utilize Osaic for its custodial services. Licensed Insurance Agents. Registrant’s Managing Member is also the Managing Member of Elite Brokerage Group, LLC d/b/a Elite Brokerage, Ltd (“Elite”), a New Jersey limited liability insurance company. In his individual capacity as a licensed insurance agent/principal of Elite, Mr. Scibetta may recommend the purchase of certain insurance- related products on a commission basis. As referenced in Item 4.B above, clients can engage certain of Registrant’s representatives to purchase insurance products on a commission basis. Conflicts of Interest: The recommendation by Registrant’s representatives that a client purchase a securities or insurance commission product presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any commission products from Registrant’s representatives. Clients are reminded that they may purchase insurance products recommended by Registrant through other, non-affiliated insurance agents. Indirect Ownership Interest Anthony Scibetta, the Registrant’s Managing Member, has a less than one tenth of a percent (0.10%) ownership interest in Advisor Group, Inc., (“AG”) which in turn is the sole shareholder of Osaic, VISION2020 Wealth Management Corp., an SEC registered investment advisor and wrap fee program sponsor (See discussion above in Items 4 and 5), and FSC Agency, Inc. a licensed insurance agency. Conflict of Interest: The recommendation by Mr. Scibetta that a client engage the services of any affiliate of AG, including Osaic, VISION2020 Wealth Management Corp. or FSC Agency, presents a material conflict of interest, as the receipt of residual compensation, by Mr. Scibetta, as an indirect owner of AG’s affiliated entities, provides an incentive to recommend the services offered by AG’s affiliated, rather than based on a particular client’s need. No client is obligated to engage the services of any of AG’s affiliated entities. D. As discussed above, the Registrant may refers certain clients to Advisor Managed Portfolios, as offered by VISION2020 Wealth Management Corp., a related SEC registered investment advisor. Registrant shall be compensated for its services by receipt of a fee to be paid by VISION2020 Wealth Management Corp. to the Registrant. In addition to 18  Registrant’s written disclosure statement as set forth in this Part 2 of Form ADV, the client shall also receive the written disclosure statement of VISION2020 Wealth Management Corp. Conflict of Interest: The recommendation by the Registrant that an individual or entity engage VISION2020 Wealth Management Corp. to service a client presents a conflict of interest, as the Registrant’s receipt of direct compensation and the Registrant’s Managing Member’s indirect receipt of compensation through his individual ownership position in AG provides an incentive to recommend the Advisor Managed Portfolios offered by VISION2020 Wealth Management Corp., rather than based upon a particular client’s need. No person or entity is under any obligation to utilize the Advisor Managed Portfolios recommended by the Registrant. A client may pay a higher or lower fee if the client obtains the services of VISION2020 Wealth Management Corp. directly, rather than through the Registrant. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. The Registrant maintains an investment policy relative to personal securities transactions. This investment policy is part of Registrant’s overall Code of Ethics, which serves to establish a standard of business conduct for all of Registrant’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, the Registrant also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by the Registrant or any person associated with the Registrant. B. Neither the Registrant nor any related person of Registrant recommends, buys, or sells for client accounts, securities in which the Registrant or any related person of Registrant has a material financial interest. C. The Registrant and/or representatives of the Registrant may buy or sell securities that are also recommended to clients. This practice may create a situation where the Registrant and/or representatives of the Registrant 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 the Registrant 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 the Registrant’s clients) and other potentially abusive practices. The Registrant has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of the Registrant’s “Access Persons”. The Registrant’s securities transaction policy requires that an Access Person of the Registrant 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 or make available to the Chief 19  Compliance Officer or his/her designee a list of reportable transactions each calendar quarter as well as a written annual report of the Access Person’s securities holdings; provided, however that at any time that the Registrant has only one Access Person, he or she shall not be required to submit any securities report described above. D. The Registrant and/or representatives of the Registrant may buy or sell securities, at or around the same time as those securities are recommended to clients. This practice creates a situation where the Registrant and/or representatives of the Registrant 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, the Registrant has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of Registrant’s Access Persons. Item 12 Brokerage Practices A. In the event that the client requests that the Registrant recommend a broker- dealer/custodian for execution and/or custodial services (exclusive of those clients that may direct the Registrant to use a specific broker-dealer/custodian), Registrant generally recommends that investment management accounts be maintained at Pershing. Prior to engaging Registrant to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with Registrant setting forth the terms and conditions under which Registrant shall manage the client's assets, and a separate custodial/clearing agreement with each designated broker-dealer custodian. Factors that the Registrant considers in recommending Pershing (or another broker- dealer/custodian, investment platform and/or mutual fund sponsor to its clients) include historical relationship with the Registrant, financial strength, reputation, execution capabilities, pricing, research, and service. Although the commissions and/or transaction fees paid by Registrant's clients shall comply with the Registrant's duty to seek best execution, a client may pay a commission that is higher than another qualified broker- dealer might charge to effect the same transaction where the Registrant determines, in good faith, that the commission/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, commission rates, and responsiveness. Accordingly, although Registrant will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commissions or transaction fees charged by the designated broker- dealer/custodian are exclusive of, and in addition to, Registrant's investment management fee. The Registrant’s best execution responsibility is qualified if securities that it purchases for client accounts are mutual funds that trade at net asset value as determined at the daily market close. 1. Research and Additional Benefits Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Registrant receives from Pershing (or another broker-dealer/custodian, investment platform, unaffiliated investment manager, vendor, unaffiliated product/fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist the Registrant to better monitor and service client accounts maintained at such institutions. Included within the support services that may be obtained by the Registrant may be 20  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, computer hardware and/or software and/or other products used by Registrant in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products that may be received may assist the Registrant in managing and administering client accounts. Others do not directly provide such assistance, but rather assist the Registrant to manage and further develop its business enterprise. Registrant’s clients do not pay more for investment transactions effected and/or assets maintained at Pershing as a result of this arrangement. There is no corresponding commitment made by the Registrant to Pershing or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. 2. The Registrant does not receive referrals from broker-dealers. 3. The Registrant does not generally accept directed brokerage arrangements (when a client requires that account transactions be effected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Registrant 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 Registrant. As a result, 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. In the event that the client directs Registrant 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 Registrant. Higher transaction costs adversely impact account performance. Transactions for directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. The Registrant’s Managing Member, Anthony N. Scibetta, remains available to address any questions that a client or prospective client may have regarding the above arrangement. B. To the extent that the Registrant provides investment management services to its clients, the transactions for each client account generally will be effected independently, unless the Registrant decides to purchase or sell the same securities for several clients at approximately the same time. The Registrant may (but is not obligated to) combine or “bunch” such orders to seek best execution, to negotiate more favorable commission rates or to allocate equitably among the Registrant’s clients differences in prices and 21  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. The Registrant shall not receive any additional compensation or remuneration as a result of such aggregation. Item 13 Review of Accounts A. For those clients to whom Registrant provides investment supervisory services, account reviews are conducted on an ongoing basis by the Registrant's Principals and/or representatives. All investment supervisory clients are advised that it remains their responsibility to advise the Registrant of any changes in their investment objectives and/or financial situation. All clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives and account performance with the Registrant on an annual basis. B. The Registrant may conduct account reviews on an other than periodic basis upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market corrections and client request. C. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. The Registrant may also provide a written periodic report summarizing account activity and performance. Item 14 Client Referrals and Other Compensation A. As referenced in Item 12.A.1 above, the Registrant receives an economic benefit from Pershing. The Registrant, without cost (and/or at a discount), receives support services and/or products from Pershing. There is no corresponding commitment made by the Registrant to Pershing or any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. B. Neither the Registrant nor any related person of the Registrant directly or indirectly compensates any person for client referrals. Item 15 Custody The Registrant shall have the ability to have its advisory fee for each client debited by the custodian on a quarterly basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. The Registrant may also provide a written periodic report summarizing account activity and performance. 22  To the extent that the Registrant provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by the Registrant with the account statements received from the account custodian. The account custodian does not verify the accuracy of the Registrant’s advisory fee calculation. Item 16 Investment Discretion The client can determine to engage the Registrant to provide investment advisory services on a discretionary basis. Prior to the Registrant assuming discretionary authority over a client’s account, the client shall be required to execute an Investment Advisory Agreement, naming the Registrant as the client’s attorney and agent in fact, granting the Registrant full authority to buy, sell, or otherwise effect investment transactions involving the assets in the client’s name found in the discretionary account. Clients who engage the Registrant on a discretionary basis may, at any time, impose restrictions, in writing, on the Registrant’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 the Registrant’s use of margin, etc.). Item 17 Voting Client Securities A. The Registrant 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. B. Clients will receive their proxies or other solicitations directly from their custodian. Clients may contact the Registrant to discuss any questions they may have with a particular solicitation. Item 18 Financial Information A. The Registrant does not solicit fees of more than $1,200, per client, six months or more in advance. B. The Registrant 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 client accounts. C. The Registrant has not been the subject of a bankruptcy petition. The Registrant’s Chief Compliance Officer, Anthony Scibetta, remains available to address any questions that a client or prospective client may have regarding the above disclosures and arrangements. 23