Independence Square Holdings, LLC

Item 1: Cover Page Independence Square Holdings, LLC Doing Business as: Independence Square Advisors FORM ADV PART 2A Appendix 1 Wrap Fee Program Brochure 150 S Warner Rd Suite 300 King of Prussia, PA 19406 (610) 520-1500 info@indsquare.com indsquare.com January 1, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Independence Square Holdings, LLC, dba Independence Square Advisors. If you have any questions about the contents of this brochure, please contact us at (610) 520-1500, by email at info@indsquare.com, or by our website www.indsquare.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. Independence Square Holdings, LLC is an SEC Registered Investment Adviser. Registration of an investment adviser does not imply a certain level of skill or training. Oral and written communications with an adviser will provide you with information with which you determine to hire or retain an adviser. Additional information about Independence Square Holdings, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Independence Square Holdings, LLC’s CRD number is: 300139. i  Item 2: Material Changes Independence Square Holdings, LLC is required to disclose a summary of material changes in this brochure from our last annual update on March 30th, 2025. Material changes generally relate to Independence Square Holdings, LLC’s policies, practices or conflicts of interest. Since our last annual update, we have: • Item 4 – Services and Fees: Updated and expanded disclosure regarding the scope of wrap fee services, permissible investment strategies (including model portfolios), discretionary versus non-discretionary account management, advisory fee billing in advance or in arrears, and wrap-specific conflicts of interest. • Item 6 – Portfolio Management: Clarified internal portfolio management responsibilities and supervisory oversight of investment adviser representatives. • Item 7 – Client Reviews: Updated disclosure regarding client review practices and minimum annual review standards. • Item 9 – Additional Information: Enhanced disclosure regarding affiliated entities and hybrid advisory relationships, updated client referral and promoter compensation disclosures, and revised financial condition disclosures. All other changes to this Brochure were routine changes. We encourage you to read this document in its entirety. If you would like another copy of this Brochure, please download it from the SEC website as indicated in Item 1, or you may contact our principal office at (610) 520-1500 or info@indsquare.com. Our brochure is also available on our website: https://indsquare.com. ii  Item 3: Table of Contents Cover Page .......................................................................................................................................... i Material Changes ............................................................................................................................... ii Table of Contents ..............................................................................................................................iii Services, Fees, and Compensation ...................................................................................................... 1 Account Requirements and Types of Clients ........................................................................................ 9 Portfolio Manager Selection and Evaluation ........................................................................................ 10 Client Information Provided to Portfolio Managers ............................................................................. 12 Client Contact with Portfolio Managers .............................................................................................. 13 Additional Information ..................................................................................................................... 13 iii  Item 4: Services, Fees and Compensation Services Independence Square Holdings, LLC, doing business as Independence Square Advisors (“INDSQUARE,” “we,” “us,” or “our”), offers ongoing portfolio management services through the Independence Square Advisors Wrap Fee Program. Services are provided based on each client’s individual investment objectives, risk tolerance, time horizon, and other relevant considerations. This Appendix 1 Brochure describes the advisory services offered under the Wrap Fee Program. Additional information regarding INDSQUARE’s other investment advisory services is available in our Form ADV Part 2A, which may be obtained through the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. Representatives who recommend the Wrap Fee Program receive compensation in connection with client participation in the program. The total cost of the Wrap Fee Program may be higher than the cost of purchasing investment advisory services, brokerage services, and other services separately. As a result, representatives may have a financial incentive to recommend the Wrap Fee Program over other available programs or service arrangements. Clients are not required to participate in the Wrap Fee Program and may select alternative advisory arrangements. Under the Wrap Fee Program, INDSQUARE provides ongoing investment advice and portfolio management of client assets on either a discretionary or non-discretionary basis, as elected by the client in the applicable Investment Advisory Agreement. When managing an account on a discretionary basis, INDSQUARE is authorized to effect transactions without obtaining prior client approval for each transaction. When managing an account on a non-discretionary basis, INDSQUARE provides investment recommendations, and the client retains final authority over the implementation of such recommendations. INDSQUARE may recommend and manage a broad range of investments within Wrap Fee Program accounts. Such investments may include, but are not limited to, mutual funds, exchange-traded funds (“ETFs”), variable annuity subaccounts, equity securities, fixed income securities, cash and cash equivalents, alternative or non-traditional investment strategies, model portfolios (whether proprietary or third-party), and other investment vehicles or strategies that INDSQUARE believes are consistent with the client’s investment objectives and restrictions. The specific investments utilized will vary based on the client’s selected investment objective, risk tolerance, time horizon, account size, and other relevant factors. Key features of the Wrap Fee Program include: • Investment Authority: Accounts are managed on a discretionary or non-discretionary basis, as specified in the client’s written Investment Advisory Agreement. • Custody and Execution: Client assets are maintained at LPL Financial LLC or Charles Schwab & Co., Inc., which serve as custodian and executing broker-dealer for transactions and provide related administrative services. • Reporting: Clients receive account statements, transaction confirmations, and performance reports from the custodian, generally on a quarterly basis or more frequently. These reports are designed to provide information regarding account activity and performance over the applicable reporting period. 4  Fees Under the Independence Square Advisors Wrap Fee Program, clients pay a single asset-based advisory fee that generally covers ongoing investment advisory services and the execution of transactions in the account. Clients do not pay separate brokerage commissions, markups, or transaction charges in addition to the wrap advisory fee for transactions executed within the program. The advisory fee is negotiated between the client and the client’s financial advisor and is set forth in the applicable advisory agreement. The advisory fee is calculated as a percentage of the total value of assets in the account, including cash, and is based on the account value as of the last business day of the applicable billing period. Fees may be billed quarterly in advance or in arrears, as specified in the client’s advisory agreement. You may terminate your advisory agreement at any time without penalty. If you terminate within five (5) business days of signing the agreement, you will receive a full refund of any fees paid in advance. After that period, any unearned portion of fees paid in advance will be refunded on a prorated basis and returned within fourteen (14) days, either by check or credited back to your account. Prorated refunds are calculated using a daily rate based on the annual advisory fee divided by 365. Fees billed and paid in arrears represent services already provided and are not refundable. The maximum advisory fee under the Wrap Fee Program is 2.50%, with no minimum advisory fee. Advisory fees may be higher than those charged by other investment advisers for similar services. Fees are paid to ISQ and shared between the firm and its associated persons. Advisory fees are deducted directly from your account by the custodian pursuant to your written authorization. Either ISQ or the custodian will calculate the fee and the custodian deducts fees quarterly in advance or arrears, depending on the terms of your advisory agreement and the custodian’s operational capabilities Brokerage, Transaction Costs, and Wrap-Specific Conflicts In a wrap fee account, clients do not pay transaction charges directly for buying or selling investments. However, the executing custodian charges transaction costs to INDSQUARE, and INDSQUARE passes those costs to its associated persons. These costs vary depending on the type of investment traded, such as mutual funds, exchange-traded funds (“ETFs”), equity securities, or fixed income securities. Some mutual funds and ETFs participate in “No Transaction Fee” (“NTF”) programs offered by custodians. Under these programs, the fund or ETF sponsor pays the custodian to cover some or all of the transaction charges that would otherwise apply. These payments are retained by the custodian and are not shared with INDSQUARE or the advisor. Because of these arrangements, advisors have an incentive to recommend investments with lower or no transaction charges, such as NTF mutual funds or ETFs, instead of investments that may carry higher transaction costs. Advisors may also have an incentive to limit trading activity in wrap accounts in order to reduce transaction costs they incur, or your advisor may 5  have an incentive to recommend investments with lower transaction charges (for example, equities instead of certain fixed income securities). These incentives are addressed through INDSQUARE’s fiduciary obligation to act in the client’s best interest. In some cases, custodians may charge asset-based fees instead of per-trade fee or they may waive transaction charges altogether. While this may reduce transaction-cost conflicts, clients do not receive any additional financial benefit from such arrangements. Transaction cost incentives differ between wrap and non-wrap accounts. In non-wrap accounts, clients pay transaction charges directly to the custodian. Because your advisor does not bear those costs, there may be less incentive to limit trading activity. Higher trading activity can increase transaction costs and may affect investment performance. Advisors may have an incentive to recommend a non-wrap program because they are not responsible for paying transaction charges. However, account fees in both wrap and non-wrap programs may reflect the overall cost structure, meaning wrap fees may be higher to account for transaction costs paid by the advisor. Clients should also understand that wrap accounts may be less cost-effective for buy-and-hold strategies, since the wrap fee includes transaction costs even if few trades occur. All of these factors can affect overall costs and investment performance. Mutual funds and ETFs that participate in NTF programs often have higher ongoing internal expenses, which may be used in part to offset the sponsor payments to the custodian. These higher expenses can reduce investment returns over time compared to other share classes or similar investments that do not participate in NTF programs. The custodian also offers an ETF NTF Network. For certain ETFs, the sponsor pays the custodian a flat fee, an asset-based fee, or both, in exchange for the custodian waiving transaction charges. In some cases, higher-cost ETFs pay higher fees to the custodian, which creates an incentive for the custodian to include those ETFs in model portfolios or programs. While these fees are not shared with INDSQUARE or your financial advisor, your advisor still has an incentive to select ETFs in the NTF Network to avoid transaction charges. incentives and conflicts when evaluating Clients should consider these investment recommendations, as they may result in higher overall fees and affect investment performance. Additional information about these programs is available on LPL Financial’s disclosures website. Please refer to the Disclosures page on www.lpl.com/disclosures.html. Mutual Fund Share Class and 12b-1 Fee Considerations As an investment adviser, INDSQUARE has a fiduciary duty under federal law to act in your best interest and not place our interests ahead of your interests. This duty applies to the services INDSQUARE agrees to provide. INDSQUARE seeks to avoid conflicts of interest when available, and when a conflict cannot be eliminated, INDSQUARE provides full and fair disclosure of the conflict and, where required, obtain your informed consent before moving forward. Mutual funds often offer different share classes. Some share classes have lower ongoing costs and do not charge 12b-1 fees, while others may have higher internal expenses, including 12b- 6  1 fees. When selecting a mutual fund for your account, your advisor considers the overall cost of the account, not just the cost of a single investment. In wrap fee accounts, transaction charges are included in the wrap fee and are paid by your advisor. Because of this structure, certain mutual fund share classes—such as A shares that typically benefit investors through lower ongoing expenses when held for long periods—may provide less benefit in a wrap account than in a non-wrap account. In addition, because your advisor pays transaction charges in wrap accounts, there is an incentive to limit trading activity to avoid those costs. This incentive is addressed through our fiduciary duty to actively manage your account in a manner consistent with your goals and the higher advisory fee charged in wrap accounts. Your advisor may select a mutual fund share class that pays 12b-1 fees even when a lower- cost share class exists if doing so is reasonable when considering the account’s overall fee structure, expected trading activity, and eligibility requirements. In some cases, lower-cost share classes may not be available to all investors or may require higher minimum investments. In other cases, there may be no equivalent lower-cost share class available. Some mutual funds and ETFs are available through a custodian’s “No Transaction Fee” (NTF) program. These investments may include 12b-1 fees. While these arrangements can reduce transaction costs for your advisor, they may also influence which investments are selected. INDSQUARE and its advisors do not keep 12b-1 fees. These fees are retained by the custodian, which is an unaffiliated Broker/Dealer, and are not shared with INDSQUARE or your advisor. When choosing mutual fund share classes, your advisor considers factors such as anticipated trading activity, account size, complexity, and the advisory fee you pay. The goal is to select investments that are reasonable and appropriate for you based on your overall costs and investment objectives. Performance-Based Fees and Side-by-Side Management (Not Applicable to Wrap Fee Accounts) Outside of the Wrap Fee Program, INDSQUARE may, in limited circumstances and where permitted under applicable law, offer or facilitate access to investment arrangements that include performance-based compensation. Such arrangements are available only to clients who meet the definition of a “qualified client” under Rule 205-3 of the Investment Advisers Act of 1940 and are offered on a negotiated, one-on-one basis. The terms, conditions, and calculation of any performance-based compensation are fully disclosed in the applicable advisory agreements, offering documents, or other governing documents. Performance-based compensation creates conflicts of interest because INDSQUARE, its affiliates, and certain executive management personnel may receive increased compensation when investments perform well. In addition, INDSQUARE may recommend or facilitate access to proprietary or affiliated investment products, including privately offered investment funds managed by an affiliated adviser, in which certain INDSQUARE executives may have ownership interests. These relationships create incentives to recommend or allocate assets to certain investments over others. 7  INDSQUARE manages multiple client accounts and investment strategies concurrently, including accounts subject to different fee structures and compensation arrangements. Managing accounts with differing fee arrangements may create conflicts of interest related to trade allocation, investment opportunities, and the allocation of time and resources among clients. INDSQUARE seeks to address these conflicts through disclosure and the adoption and enforcement of written policies and procedures designed to promote fair and equitable treatment of clients. Other Fees and Charges In addition to the advisory fee you pay to INDSQUARE, your wrap account may incur other fees and charges from parties that are not part of INDSQUARE. These fees are separate from and in addition to our advisory fee. INDSQUARE does not receive any portion of these other fees. The custodian that holds your account may charge fees for services such as: • Account maintenance or service fees • Wire transfer or electronic fund fees • Fees for certain custodial or trust services • Regulatory or transaction fees required by law • Charges when moving your account to another firm • Markups, Markdowns, or spreads These fees are explained by the custodian when your account is opened and are generally deducted directly from your account. If your account is invested in mutual funds or other pooled products: • You pay the fund’s internal fees and expenses (called an expense ratio), which can include 12b-1 or service fees. These costs are not part of the wrap fee and reduce the value of your investment over time. • Some mutual funds may charge fees for early redemption, contingent deferred sales charges, or frequent trading charges as described in the fund’s prospectus. • Even no-load or NTF (No Transaction Fee) funds can have ongoing internal costs. If your account includes variable annuities or other insurance-linked products: • You may pay mortality and expense charges, administrative fees, contract rider fees, and charges for excessive transfers, as detailed in the product prospectus. Depending on the investments and services, there may be other charges imposed by third parties, such as: • Taxes, duties, or transfer taxes 8  • Fees related to trading on foreign exchanges • Fees for processing certain types of securities or account activities • Fees charged by product sponsors, custodians, or issuers that are not part of the wrap fee These are not collected by INDSQUARE and are described in the governing documents of the investments or by the service provider. For detailed information about fees charged by a specific mutual fund, ETF, variable annuity, or other investment, please review the investment’s prospectus or offering document, which is available from INDSQUARE or directly from the product sponsor. Other Important Considerations • The advisory fee is a single wrap fee that covers ongoing investment advisory services, execution of transactions, and certain administrative and custodial services. This fee may be higher than the cost of purchasing these services separately, such as paying an advisory fee and separate transaction charges. Whether the wrap fee is more or less costly depends on factors such as the size of your account, the anticipated number and type of transactions, and the scope of advisory and client services provided. • The wrap fee may also be higher than the cost of holding assets in a traditional brokerage account. In a brokerage account, you generally pay a commission for each transaction and do not receive ongoing investment advice or account monitoring. If you expect limited trading activity or do not want ongoing advisory services, a brokerage account may be more appropriate than a wrap fee account. • INDSQUARE and your advisor receive compensation because of your participation in the wrap program. This compensation includes an advisory fee and may also include non- cash compensation, such as bonuses, awards, or other benefits provided by the custodian to INDSQUARE or its associated persons. The amount of compensation may differ from what INDSQUARE, or your advisor would receive under other advisory arrangements or if services were paid for separately. As a result, INDSQUARE and your advisor have a financial incentive to recommend the wrap program over other programs or services. • The investment products available through the wrap program are generally available outside of the program and may be purchased through broker-dealers or other investment firms not affiliated with INDSQUARE. Item 5: Account Requirements and Types of Clients The wrap program generally does not require a minimum account size. However, certain investments available through the program may impose minimum investment requirements, and your advisor may establish minimum account sizes for accounts they agree to manage. 9  The wrap program is available to individuals, corporations, high-net-worth individuals, charitable organizations, and other eligible clients. Item 6: Portfolio Manager Selection and Evaluation Under the Wrap Fee Program, INDSQUARE provides ongoing investment advice and portfolio management for assets held in your account. INDSQUARE does not select, review, or recommend unaffiliated third-party investment advisers or portfolio managers within the wrap program. Portfolio management services are provided by INDSQUARE and your advisor. In managing wrap program accounts, INDSQUARE may use model portfolios or model-based investment strategies, which may be applied consistently across accounts with similar objectives, subject to client-specific circumstances and restrictions Your advisor evaluates and manages your portfolio based on your stated investment objectives, risk tolerance, time horizon, liquidity needs, and any reasonable restrictions you provide in writing. Portfolio decisions are reviewed on an ongoing basis, considering changes in market conditions, investment performance, and individual circumstances. INDSQUARE oversees your advisor’s activities through supervisory and compliance processes designed to promote consistency with client objectives and firm policies. This oversight may include reviews of portfolio activity, adherence to investment guidelines, and monitoring of account suitability. Accounts managed under the wrap program are generally managed using the same investment approach as non-wrap advisory accounts. However, fees and cost structures may differ, and the wrap fee may be higher than fees charged in other advisory arrangements. information, acknowledgements, and terms related Additional account to portfolio management are set forth in your advisory agreement and account application. For more information about your advisor managing your account, you should refer to the Brochure Supplement for the associated person, which you should have received along with this Brochure at or before the time you opened your account. If you would like another copy of it, you can obtain it by reaching out to our main office via the contact information listed on the cover page of this document. Types of Advisory Services Investment adviser representatives provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), variable annuity subaccounts, real estate investment trusts (“REITs”), equities, and fixed income securities. Their advice is tailored to the individual needs of each client based on the investment objective chosen by the client to help assist clients in attempting to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary according to each client’s investment profile. INDSQUARE evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. We request discretionary authority from you in order to select securities and execute transactions without permission from you prior to each transaction. Risk tolerance levels are documented at the time of account opening and it is your responsibility to promptly notify us if there is any change in your financial situation or investment objectives so we can review, evaluate, or if necessary, revise the way we manage your account(s). INDSQUARE seeks to make investment decisions that are in accordance with the fiduciary 10  duties owed to its accounts and without consideration of our own economic, investment, or other financial interests. To meet our fiduciary obligations, INDSQUARE attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, INDSQUARE’s policy is to seek fair and equitable allocation of investment opportunities/transactions among our clients to avoid favoring one client over another over time. It is INDSQUARE’s policy to allocate investment opportunities and transactions we identify as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among our clients on a fair and equitable basis over time. Client-Tailored Services and Client-Imposed Restrictions INDSQUARE tailors its Wrap Program services to each client based on individual goals, needs, and circumstances. This process typically includes discussions to understand your objectives, risk tolerance, time horizon, and any specific preferences, followed by the development and ongoing management of an investment strategy designed to address those factors. INDSQUARE may use model allocations, along with customized investment recommendations, to manage your account. You may place reasonable restrictions on investing in certain securities or types of investments based on your preferences, values, or beliefs, provided those restrictions are communicated to us in writing. If requested restrictions materially limit our ability to manage your account effectively or require us to deviate from the standard services offered through the Wrap Program, INDSQUARE may decline to implement the restrictions or may determine that it is appropriate to terminate the advisory relationship. Methods of Analysis INDSQUARE’s methods of analysis include: Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis, and Technical analysis. Charting analysis involves the use of patterns in performance charts. INDSQUARE uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. 11  Technical analysis involves the analysis of past market data, primarily price and volume. Investment Strategies INDSQUARE uses long term trading, short term trading, short sales, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing involves risks including possible loss of principal. No investment strategy or risk management technique can guarantee return or eliminate risk in all market environments. Voting Client Securities INDSQUARE will not ask for, nor accept, voting authority for client securities. You will receive proxies directly from the issuer of the security or the custodian and you retain sole responsibility for voting. You should direct all proxy questions to the issuer of the security. Item 7: Client Information Provided to Portfolio Managers Under INDSQUARE’s Wrap Fee Program, INDSQUARE is responsible for managing your account, and there is no separate portfolio manager involved. INDSQUARE works with you to gather relevant financial information and to help you select an appropriate investment objective for your account. This information is obtained through your advisory agreement and related account documentation. You should notify INDSQUARE promptly of any material changes in your financial situation, investment objectives, or preferences, or if you wish to add, remove, or modify any reasonable investment restrictions. The investment objective selected for your account applies to the account as a whole and may not be reflected in the performance of every individual investment at all times. Investment objectives are long-term goals, and no particular outcome or level of performance can be guaranteed. INDSQUARE’s policy is to conduct at least one client review every twelve (12) months to determine whether there have been any changes to your financial circumstances, investment objectives, or restrictions. These reviews also generally include a discussion of account performance, the ongoing appropriateness of the account, and other information relevant to your situation. Reviews may be conducted by phone, in person, by video conference, or through other reasonable means. During these reviews, your advisor typically considers topics such as: • Your financial situation • Risk tolerance • Time horizon Investment objectives and goals • 12  • Asset allocation • Account holdings In addition, your advisor reviews advisory accounts on a periodic basis, including quarterly performance reviews, to monitor progress toward stated objectives and to determine whether adjustments may be appropriate. Item 8: Client Contact with Portfolio Managers You should contact INDSQUARE or your representative directly at any time with questions regarding your program account. Item 9: Additional Information Disciplinary Information As a Registered Investment Adviser, INDSQUARE is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of our advisory business or the integrity of our management. INDSQUARE and our management personnel have no reportable disciplinary events to disclose. Other Financial Industry Activities and Affiliations INDSQUARE is an investment adviser that provides investment advisory services to its clients. Certain Investment Adviser Representatives (“IARs”) of INDSQUARE are also dually registered as registered representatives of LPL Financial LLC (“LPL”), a broker-dealer and SEC-registered investment adviser. When acting in their capacity as registered representatives of LPL, such individuals may engage in brokerage activities and receive transaction-based compensation, including commissions, sales charges, trails, or other remuneration, in accordance with LPL’s policies and procedures. INDSQUARE is under common ownership with ISQ Capital LLC through ISQ Holdings Ltd., and the executive management team of INDSQUARE is the same executive management team of ISQ Capital LLC. As a result, certain executive management personnel serve in advisory, supervisory, compliance, and operational roles across affiliated entities, while each firm remains a separate legal entity with distinct regulatory obligations. In connection with INDSQUARE’s hybrid advisory model, certain executive management personnel and associated persons may serve in supervisory or compliance-related roles with respect to brokerage activities conducted through LPL, including service in Office of Supervisory Jurisdiction (“OSJ”) or similar supervisory capacities. Brokerage and insurance activities conducted through LPL are supervised by LPL pursuant to its supervisory structure, Advisor Compliance Manual, and written policies and procedures, and remain subject to applicable FINRA, SEC, and insurance regulations. When individuals act in their capacity as investment adviser representatives of INDSQUARE, they are subject to INDSQUARE’s supervision, policies, and procedures as a registered investment adviser. When acting in their capacity as registered representatives of LPL, those 13  activities are conducted separately from INDSQUARE’s advisory business and are subject to LPL’s supervision. Certain fixed insurance or other outside business activities conducted away from INDSQUARE and LPL are not supervised by INDSQUARE and are governed by the applicable insurance carrier, general agency, or other supervising entity. These affiliations and multiple roles may give rise to conflicts of interest, including conflicts related to compensation, supervision, and the allocation of time and resources. INDSQUARE seeks to address such conflicts through disclosure, by clearly identifying the capacity in which services are provided, and through the adoption and enforcement of written policies and procedures designed to promote fair and equitable treatment of clients. Code of Ethics INDSQUARE takes pride in our commitment to serving our clients’ needs with integrity, and as such, we have developed a Code of Ethics to address issues; such as: • Compliance with Laws and Regulations • Conflicts of Interest • Prohibited Purchases and Sales • Political and Charitable Contributions • Gifts and Entertainment • Confidentiality • Compliance Officer Duties • Personal Transaction Reporting • Reporting Violations Each person associated with INDSQUARE has been given a copy of the Code of Ethics and has submitted an acknowledgement attesting to their understanding of the Code and acceptance of its terms. A copy of our Code of Ethics is available to all current and/or prospective clients upon request. Recommendations Involving Material Financial Interests INDSQUARE does not recommend that clients buy or sell any security in which INDSQUARE, or any person related to us, has a material financial interest. Investing Personal Money in the Same Securities as Clients From time to time, representatives of INDSQUARE may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives to buy or sell the same securities before or after recommending the same securities to clients, resulting in representatives profiting from the recommendations they provide to clients. Such transactions may create a conflict of interest. INDSQUARE documents transactions that could be construed as a conflict of interest, and it is our policy to never engage in trading that operates to a client’s disadvantage when similar securities are bought or sold. 14  Review of Accounts Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Representatives of the firm provide ongoing oversight of investments for accounts managed on a discretionary basis. Client accounts are reviewed periodically to assess whether portfolio holdings remain consistent with the applicable investment strategy and the client’s stated investment objectives. The frequency and scope of such reviews may vary based on factors such as the type of account, investment strategy, market conditions, and client circumstances. Accounts receiving ongoing advisory services are subject to supervisory review in accordance with the firm’s compliance policies and procedures. Such reviews are conducted by appropriate supervisory or compliance personnel or their designees. Financial planning and consulting engagements are generally reviewed in connection with the preparation and delivery of the applicable plan or report. Financial planning services are typically provided on a one-time basis unless otherwise agreed in writing. Following delivery of a financial plan, the firm does not provide ongoing monitoring or updates unless the client separately engages the firm for additional planning services or ongoing advisory services, which may be subject to additional fees. Clients may request additional planning services, updates, or reports at a later date pursuant to a new or amended agreement and applicable fee arrangement. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in your financial situation (such as retirement, termination of employment, physical move, or inheritance). Content and Frequency of Regular Reports Provided to Clients You will receive statements (at minimum quarterly except for some insurance and annuity products) and confirmation of transactions from the custodian and not from INDSQUARE. Financial Planning and Consulting clients will not receive regular reports but may receive written reports from our representatives at their financial planning review sessions. These reports may include descriptions of holdings, total assets, current values, management fees, the method of fee calculation, or other details or analyses agreed to between you and our representative. Each financial planning client will receive the financial plan upon completion. Client Referrals and Other Compensation Economic Benefits Provided by Third Parties for Advice Rendered to Clients INDSQUARE may receive noncash compensation from third party advisers to which INDSQUARE directs clients or from firms that manage investment products that INDSQUARE selects for our clients. 15  In addition, LPL Financial and Charles Schwab & Co., Inc. make available to INDSQUARE some products and services that benefit us but may not benefit our clients’ accounts. These benefits may include national, regional or firm-specific educational events organized and/or sponsored by LPL Financial or Charles Schwab & Co., Inc. Other potential benefits may include occasional business entertainment of our personnel including meals, invitations to sporting events, golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. LPL Financial and Charles Schwab & Co., Inc. also provide INDSQUARE with access to research, trading, and custody services which are typically not available to retail investors. Compensation to Non–Advisory Personnel for Client Referrals INDSQUARE may enter into written referral or solicitation arrangements with unaffiliated third parties (“promoters”) who introduce prospective clients to the Adviser. Any such arrangements are structured to comply with the Investment Advisers Act of 1940, including Rule 206(4)-1 thereunder, as well as applicable state securities laws. Under these arrangements, promoters may receive compensation from INDSQUARE for successful client referrals. Compensation may be structured as a retainer, a fixed fee per referred client, a percentage of advisory fees received, a percentage of capital introduced, or another mutually agreed-upon arrangement, as set forth in a written agreement between INDSQUARE and the promoter. Such agreements generally may be terminated by either party in accordance with their terms. INDSQUARE provides required disclosures regarding promoter arrangements to affected clients at or prior to the time of engagement, including disclosure of the nature of the referral relationship and the compensation paid to the promoter. Clients are not charged additional fees because of these arrangements, and the cost of any promoter compensation is borne entirely by your IAR. Financial Information Balance Sheet INDSQUARE neither requires, nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients In response to the COVID-19 pandemic and related market conditions, Independence Square Holdings, LLC (“INDSQUARE”) participated in the Paycheck Protection Program (“PPP”) established under the CARES Act to support business continuity and employee payroll. The PPP loan was used primarily to continue payroll and operating expenses during that period and was subsequently forgiven in full in accordance with program requirements. 16  INDSQUARE does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. The firm continues to operate as a going concern and maintains sufficient financial resources to provide advisory services to its clients. Bankruptcy Petitions in Previous Ten Years INDSQUARE has not been the subject of a bankruptcy petition in the last ten years. 17 

Item 1: Cover Page Independence Square Holdings, LLC Doing Business as: Independence Square Advisors FORM ADV PART 2A FIRM BROCHURE 150 South Warner Road Suite 300 King of Prussia, PA 19406 (610) 520-1500 info@indsquare.com https://indsquare.com March 4, 2026 This brochure provides information about the qualifications and business practices of Independence Square Holdings, LLC (dba Independence Square Advisors). If you have any questions about the contents of this brochure, please contact us at (610) 520-1500 or by email at: info@indsquare.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. Independence Square Holdings, LLC is an SEC Registered Investment Adviser. Registration of an investment adviser does not imply a certain level of skill or training. The oral and written communications with an adviser will provide you with information with which you determine to hire or retain an adviser. Additional information about Independence Square Holdings, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Independence Square Holdings, LLC’s CRD number is: 300139. i  Item 2: Material Changes Independence Square Holdings, LLC is required to disclose a summary of material changes in this brochure from our last annual update. Material changes generally relate to Independence Square Holdings, LLC’s policies, practices, or conflicts of interests. Since our last annual update on March 30, 2025: • Firm structure and affiliations: Expanded disclosure of INDSQUARE’s corporate structure, including its status as a wholly owned subsidiary of ISQ Holdings Ltd., affiliated entities, shared management, and relationships with ISQ Capital LLC and affiliated private investment funds. • Private fund activities: Added comprehensive disclosure regarding private fund management activities, including affiliated proprietary funds, ownership interests, side-by-side management conflicts, and performance-based compensation at the affiliate level. • Advisory services and advisor capacity: Clarified and expanded descriptions of advisory services, including discretionary and non-discretionary management, use of model portfolios, retirement plan and participant services, and distinctions among hybrid advisors, independent financial advisors, promoters, and other advisor classifications. • Expanded ancillary and third-party services: Added or enhanced disclosures regarding access to and facilitation of third-party services, including cash management programs, insurance and healthcare planning tools (including Caribou), estate planning document platforms, mortgage and lending services through NMLS-licensed advisors, technology platforms, and limited digital asset or cryptocurrency-related services. • Fees, billing practices, and compensation: Clarified advisory fee billing practices (including billing in advance or arrears), fee proration and termination treatment, fixed and hourly fee arrangements, ancillary and platform-based fees, and additional compensation received through referrals, insurance, lending, or affiliated activities. • Conflicts of interest: Expanded conflicts disclosures related to affiliated private funds, referral arrangements, outside compensation, platform and technology fees, insurance and lending activities, healthcare planning services, and other economic incentives that may influence recommendations. • Compliance and operational disclosures: Enhanced disclosures regarding compliance oversight, custodial and third-party relationships, identity verification practices, and supervisory controls applicable to advisory and ancillary services. Other routine changes have been made to this brochure. If you would like another copy of this Brochure, please download it from the SEC website as indicated in Item 1, or you may contact our principal office at (610) 520-1500 or info@indsquare.com. Our brochure is also available on our website: indsquare.com. We encourage you to read this document in its entirety. ii  Item 3: Table of Contents Cover Page ........................................................................................................................................... i Material Changes................................................................................................................................ ii Table of Contents ............................................................................................................................. iii Advisory Business............................................................................................................................... 1 Fees and Compensation ................................................................................................................... 15 Performance-Based Fees and Side-By-Side Management ...................................................................... 29 Types of Clients ................................................................................................................................ 31 Methods of Analysis, Investment Strategies, & Risk of Loss .................................................................. 31 Disciplinary Information .................................................................................................................... 38 Other Financial Industry Activities and Affiliations .............................................................................. 38 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................. 42 Brokerage Practices ........................................................................................................................... 43 Review of Accounts ........................................................................................................................... 44 Client Referrals and Other Compensation ........................................................................................... 45 Custody ............................................................................................................................................ 46 Investment Discretion ........................................................................................................................ 47 Voting Client Securities (Proxy Voting) ................................................................................................ 47 Financial Information ........................................................................................................................ 48 iii  Item 4: Advisory Business A. Description of the Advisory Firm Independence Square Holdings, LLC (hereinafter “INDSQUARE,” “Adviser,” “we,” “us,” or “our”) is a limited liability company organized under the laws of the Commonwealth of Pennsylvania. INDSQUARE is a wholly owned subsidiary of ISQ Holdings Ltd., a holding company formed in 2025 and governed under the laws of the Commonwealth of Pennsylvania. ISQ Holdings Ltd. was established solely as a holding company and did not acquire INDSQUARE through a purchase or sale transaction. INDSQUARE continues to operate as the registered investment adviser and remains solely responsible for providing investment advisory services to its clients. INDSQUARE was formed in June 2019 for the purpose of assisting clients with building, managing, and preserving their wealth. The Adviser generally manages client accounts on a discretionary basis; however, non-discretionary arrangements are also available. In addition, for certain clients subject to regulatory, employer, or other external restrictions, the Adviser may offer a fully discretionary arrangement pursuant to which the Adviser does not accept client-directed trading instructions. Investment advisory services are provided by individuals associated with INDSQUARE who are appropriately licensed, qualified, and authorized to provide advisory services on behalf of the firm. These individuals are referred to as Investment Adviser Representatives (“IARs”). INDSQUARE may also engage individuals registered solely as promoters. A promoter refers prospective clients to the Adviser but does not provide investment advice. In certain jurisdictions, promoters are not required to qualify as IARs by examination and may only refer advisory business to an IAR who is responsible for providing investment advice. Independent Financial Advisors (“IFAs”) are Investment Adviser Representatives of INDSQUARE who are licensed to provide advisory services on behalf of the firm and who are not dually registered as agents or registered representatives of a broker-dealer. Hybrid Advisors are Investment Adviser Representatives of INDSQUARE who are also dually registered as registered representatives of LPL Financial LLC (“LPL”), a registered investment adviser, member FINRA/SIPC. When acting in their capacity as IARs of INDSQUARE, Hybrid Advisors provide investment advisory services pursuant to INDSQUARE’s advisory agreements and fiduciary obligations. When acting in their capacity as registered representatives of LPL, Hybrid Advisors provide brokerage services through LPL, and such services are governed by LPL’s policies, procedures, and applicable brokerage agreements. Clients are advised that the capacity in which a Hybrid Advisor is acting will be disclosed at the time services are provided. B. Types of Advisory Services Portfolio Management Services INDSQUARE offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. We work with you to collect personal information which includes, but is not limited to, income, expenses, taxes, 1  and risk tolerance. We will either construct a portfolio customized to your specific situation, discuss utilizing a third-party asset manager, or recommend a modeled portfolio that fits your needs. Portfolio management services include, but are not limited to, the following: Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring • INDSQUARE evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. We request discretionary authority from clients to select securities and execute transactions without permission from you prior to each transaction; however, in some situations, clients may request to remove discretionary authority. is to seek fair and equitable allocation of INDSQUARE seeks to make investment decisions that are in accordance with the fiduciary duties owed to our clients and without consideration of our own economic, investment, or other financial interests. To meet our fiduciary obligations, INDSQUARE attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, investment INDSQUARE’s policy opportunities/transactions among our clients to avoid favoring one client over another over time. It is INDSQUARE’s policy to allocate investment opportunities and transactions we identify as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have limited supply among our clients on a fair and equitable basis over time. INDSQUARE may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, we confirm that those other advisers are properly licensed or registered as an investment adviser. INDSQUARE conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings, and review of the third-party adviser's performance and investment strategy. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by the third-party adviser on behalf of INDSQUARE's client. We may also allocate among them one or more private equity funds or private equity fund advisers. We review the ongoing performance of the third-party adviser as a portion of your portfolio. Services Limited to Specific Types of Investments Generally, we limit our investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds, and private placements. In certain cases, we may use other securities or investments, when appropriate, to help diversify a portfolio (please see the section on cryptocurrency, below). Private Fund Management Services Independence Square Holdings, LLC (“INDSQUARE”) does not serve as the investment 2  manager to any privately offered pooled investment vehicles. However, certain members of INDSQUARE’s executive management team are also principals and owners of one or more privately offered pooled investment vehicles (each, a “Private Fund”) and participate in the advisory and management of such Private Funds through their roles with ISQ Capital LLC, an affiliated investment adviser under the common ownership of ISQ Holdings Ltd. The Private Funds are proprietary investment products of ISQ Capital LLC. The Private Funds are offered pursuant to exemptions from registration under the Securities Act of 1933 and are not registered as investment companies under the Investment Company Act of 1940. Interests in such Private Funds are offered only to investors who meet applicable eligibility, suitability, and qualification requirements. ISQ Capital LLC serves as the investment manager to the Private Funds and is responsible for implementing the applicable investment strategies, making portfolio investment decisions, and managing the day-to-day investment activities of each Private Fund, subject to the terms of the applicable governing documents. ISQ Capital’s authority generally includes discretion to select securities and other investments, determine position sizing and portfolio composition, execute transactions, and manage risk consistent with each Private Fund’s stated investment objectives and restrictions. The Private Funds may invest across a range of asset classes and instruments, which may include, among other things, equity securities, fixed income securities, derivatives, leverage, and other investment techniques permitted under the applicable fund documents. Investment strategies may involve active trading, use of leverage, hedging strategies, and concentrated positions, and may result in a higher degree of risk than traditional long-only investment strategies. Private Fund investors are generally institutional investors, family offices, and high-net- worth individuals who meet the definition of “accredited investor” and, where applicable, “qualified client” under federal securities laws. Investors in Private Funds do not have direct ownership of the underlying investments and do not receive individualized investment advisory services from INDSQUARE. The compensation received by ISQ Capital LLC for managing the Private Funds typically consists of an asset-based management fee and, in certain cases, a performance-based allocation or fee, as permitted under applicable law. Fee structures, expense allocations, liquidity terms, and withdrawal rights are described in the applicable offering and governing documents of each Private Fund. Certain investors may be subject to different fee arrangements or terms, including fee reductions or waivers. The management of Private Funds by ISQ Capital LLC may give rise to conflicts of interest, including those related to proprietary product sponsorship, ownership interests of management personnel, performance-based compensation, allocation of investment opportunities, side-by-side management of accounts, and differing fee structures among clients. These conflicts are disclosed and managed in accordance with ISQ Capital LLC’s fiduciary obligations and compliance policies, and additional information regarding such conflicts is provided elsewhere in the applicable disclosure documents. LPL Financial Sponsored Advisory Programs INDSQUARE may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL), a registered investment adviser and broker-dealer. Below is a brief 3  description of each LPL advisory program available to INDSQUARE. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. Manager Access Select Program Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. INDSQUARE will assist clients in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages the client’s assets on a discretionary basis. INDSQUARE provides both initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, clients authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. INDSQUARE assists clients in determining the suitability of OMP for the client and assists the client in setting an appropriate investment objective. INDSQUARE has discretion to select a mutual fund asset allocation portfolio, designed by LPL, consistent with the client’s investment objective. LPL has discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have the authority to rebalance the account. A minimum account value of $1,000 and systematic contributions of at least $25 per year are required for OMP. Without systematic contributions, the minimum investment amount is $10,000. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. INDSQUARE has discretion to select the asset allocation model portfolio based on our client’s investment objective. We also have discretion to select third party money managers (PWP Advisors), mutual funds, and ETFs within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell, on a discretionary basis, mutual funds, ETFs and equity and fixed income securities. 4  A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. INDSQUARE will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program, and assist the client in setting an appropriate investment objective. INDSQUARE will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio, designed by LPL’s Research Department, that is consistent with the client’s stated investment objective. LPL’s Research Department or third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to rebalance their MWP account(s). MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Small Market Solution (SMS) Program Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a series of different investment menus (“Investment Menus”) consisting of a mix of different asset classes and investment vehicles (“investment options”) for clients that sponsor and maintain participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it believes is appropriate based on the demographics and other characteristics of the Plan and its participants. LPL Research is responsible for the selection and monitoring of the investment options made available through Investment Menus (“Fiduciary Selection Services”). The investment options that are offered through SMS are limited to the specific investments available through the record keeper that the Plan Sponsor selects. The Plan Sponsor may only select an Investment Menu in its entirety and does not have the option to remove or substitute an investment option. If the Plan is subject to ERISA, LPL will be a “fiduciary” and serve as “investment manager” (as that term is defined in section 3(38) of ERISA) in connection with the Fiduciary Selection Services. None of the services offered under SMS other than the Fiduciary Selection Services will constitute “investment advice” under 3(21)(A)(ii) of ERISA, or otherwise cause LPL or INDSQUARE to be deemed a fiduciary. In addition to the Fiduciary Selection Services, the Plan Sponsor may also select from a number of non-fiduciary consulting services available under SMS that are provided by INDSQUARE. These consulting services may include, but are not limited to, general education, and support regarding the Plan and the investment options selected by Plan 5  Sponsor; assistance regarding the selection of, and ongoing relationship management for, record keepers and other third-party vendors; Plan participant enrollment support; and participant-level education regarding investment in the Plan. These consulting services do not include any individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets, and LPL and INDSQUARE do not act as fiduciaries under ERISA in providing such consulting services. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell open-end mutual funds and exchange-traded funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of Xulu, Inc., doing business as FutureAdvisor (“FutureAdvisor”), based upon model portfolios constructed by LPL, and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although INDSQUARE will be available to discuss investment strategies, objectives, or the account in general in person or via telephone. (45) A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor, and INDSQUARE by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor, or INDSQUARE, do not enter into an advisory agreement with LPL, FutureAdvisor, or INDSQUARE, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. Pension Consulting Services INDSQUARE offers consulting services to pensions or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: identifying investment objectives and restrictions; and/or • • providing guidance on various asset classes and investment options; and/or • recommending money managers to manage plan assets in ways designed to achieve objectives; and/or • monitoring performance of money managers and investment options and making recommendations for changes; and/or • recommending other service providers, such as custodians, administrators, and 6  broker-dealers; and/or • creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Retirement Plan Participant Advisory Services (ERISA Accounts) Independence Square Holdings, LLC offers non-discretionary investment advisory services to participants in employer-sponsored retirement plans, including plans governed by the Employee Retirement Income Security Act of 1974 (“ERISA”), such as 401(k) plans, as well as other tax-qualified retirement accounts. Participation in these advisory services is entirely optional, and plan participants are not required to engage the Adviser. These services are not offered by all Investment Adviser Representatives of Independence Square Holdings, LLC. Only certain IFAs of the Adviser offer this service, and participants should confirm with their assigned IAR whether the service is available. Under this service, the Adviser provides individualized investment recommendations and ongoing guidance based on the participant’s financial circumstances, investment objectives, and risk tolerance. The Adviser does not have discretionary authority over the participant’s retirement account and does not execute transactions or make changes to the account. All investment decisions, including whether and when to implement any recommendation, remain solely with the participant. When providing advisory services to participants in ERISA-governed plans, the Adviser acts as a fiduciary within the meaning of ERISA Section 3(21), limited to the scope of the non-discretionary investment advice provided. The Adviser does not serve as an ERISA Section 3(38) investment manager and does not assume responsibility for plan administration, plan-level investment selection, or assets held outside the participant’s account. Investment recommendations provided under this service are limited to the investment options made available to the participant or the self-directed brokerage option (“SDB”) if permitted under the applicable plan document and through the plan’s recordkeeper or platform. The Adviser does not have the ability to recommend investments outside of the plan’s designated investment alternatives and does not have authority to modify or expand the plan’s available investment menu. As a result, the range of investment options available to participants may be more limited than those available in other advisory relationships. See section 5(A) for information regarding fees and conflicts of interest. Financial Planning and Consulting INDSQUARE provides its clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment-related matters). These services are tailored to the individual needs of each client. As a general matter, the Adviser does not provide legal or tax advice in connection with these services. In limited circumstances, an Investment Adviser Representative (“IAR”) of INDSQUARE who is 7  separately licensed as a tax professional, such as an Enrolled Agent or Certified Public Accountant, may provide tax advice solely in their capacity as part of an approved outside business activity and not in their role as an IAR of INDSQUARE. In all cases, clients are encouraged to consult with their own legal and tax advisors regarding their specific circumstances. In performing our services, we are not required to verify any information received from you or your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on such information. Certain employees of INDSQUARE include individuals who are licensed insurance agents or registered representatives of an unaffiliated broker-dealer who may implement its recommendations for certain products as part of the overall client portfolio. Clients are advised that a conflict of interest exists if we recommend our own services or those of our employees or affiliates. You are under no obligation to act upon any of the recommendations made by us under financial planning or consulting engagement or to engage the services of any such recommended professional, including, by INDSQUARE itself. You retain absolute discretion over all such implementation decisions, and you are free to accept or reject any of our recommendations. It remains your responsibility to promptly notify us if there is any change in your financial situation or investment objectives so we can review, evaluate, or if necessary, revise our previous recommendations and/or services. Wealth Inc. (“Wealth.com”) INDSQUARE may provide you access to Wealth Inc.’s third-party technology platform, “Wealth.com”. This platform presents financial advisors with the unique opportunity to provide a value-added service to clients by granting them access to estate planning, templated documents. Wealth.com templates include Last Will and Testament, Financial Power of Attorney, Advanced Health Care Directives, Guardianship Nominations, Revocable Trust & Pourover Wills. Wealth.com templates are fillable and must be completed by you, not your financial advisor. Neither Wealth Inc. nor INDSQUARE is, or will, provide tax or legal advice. If you are seeking tax or legal advice, please consult with an attorney or a tax professional. Wealth.com templates are available in, all 50 U.S. states and D.C. These documents may not be valid internationally, and if you are considering moving out of the United States, you should consult with an attorney. Templates are generic and do not encompass all situations. Templates are not tailored to your specific needs and therefore, if you have a unique situation or special circumstances, we recommend you discuss these situations with an attorney prior to utilizing Wealth.com templates. If your financial advisor recommends Wealth.com, they may have a financial incentive for doing so, which would be a conflict of interest. Your financial advisor is paying an ongoing licensing fee for access to the Wealth.com platform. Your financial advisor will pay this fee regardless of if you utilize this service or not. Some advisors may charge a one-time fee for the initial creation of these documents, some advisors may charge a monthly fee, while other advisors may not charge a fee at all and only provide this service as a value- added to his/her clients. Prior to utilizing this service, please discuss the fees with your financial advisor and make sure you fully understand the costs. Since each advisor determines their fee structure up to the maximum amounts allowed the presence of a conflict of interest may be different for each advisor. Regardless, it is important to know that if your financial advisor is charging for this service, your financial advisor has a financial incentive to recommend you utilize this provider. Please review section 5(A) for 8  additional information regarding fees for this service. As part of the Master service Agreement between your advisor and Wealth Inc., your advisor is prohibited from participating in the promotion, sponsorship, sale, or otherwise recommend the services of any third-party software-based estate planning or estate document creation services other than Wealth.com. This does not include non- software-based services provided by traditional law firms. Due to this restriction, your advisor has a conflict of interest concerning where they refer you to for software-based estate planning or estate document creation services. Wealth Inc. is not a financial planner, or an investment, financial, tax, or legal advisor. The service is not intended to provide investment, legal, tax, or financial advice. The information provided by Wealth Inc., along with the content of their Service related to legal matters ("Legal Information"), is provided for your private use, and does not constitute legal advice regardless of whether you specifically solicited the information or otherwise. Wealth Inc. provides a platform for Legal Information and self-help. If you are a user who accesses the Service with a license that allows you to create estate planning documents (“End User”), the Service is intended only to assist you in decision- making in connection with estate planning and asset management based on a finite set of data about you. Options presented are based on certain assumptions and the data we have considered. Your personal financial situation is unique and dependent on many circumstances and factors not captured by the Service, and any information and recommendations obtained through the Service may be given without knowledge of, access to, or consideration of such other circumstances and factors. Additionally, Wealth Inc. does not (i) review any information you provide for legal accuracy or sufficiency, (ii) restrict you from making your own legal conclusions (including your selection of forms), or (iii) apply the law to the facts of your situation by soliciting information from you as an attorney or in-person advisor would. Before you make any final decisions concerning your estate plan or implement any other financial strategy, you should obtain additional information and advice from a licensed attorney, accountant, and other legal and financial advisors who are fully aware of your individual circumstances. The service is not a replacement for personal advice from a licensed attorney, accountant, or other legal and financial advisors. Also, any recommendation we make may have many recommendation components that work together to achieve an optimal result. If you choose not to follow each and every recommendation, the result may not have the desired outcome. Legal Information provided by Company through its Service is not a substitute for legal advice from a qualified attorney licensed to practice in an appropriate jurisdiction. Communications between you, Wealth Inc., and your financial advisor will not be protected as privileged communications under the attorney-client privilege or work product doctrine. You are solely responsible for determining the appropriateness of using, and applicability to you of, any documents, work product, or information produced by the Service. Please review all Terms and Conditions, End User Agreements, Disclosures and Disclaimers, etc. provided by Wealth Inc. prior to employing this service. Cash Management Services INDSQUARE may make available to clients the FICA For Advisors cash management 9  program (“FICA Program”) offered by StoneCastle Network, LLC (“StoneCastle”), an affiliate of StoneCastle Cash Management, LLC. The FICA Program allows customers the ability to protect their money by placing it in deposit accounts at banks, savings institutions, and credit unions (collectively, “Insured Depositories”) in a manner that seeks to maintain full insurance of the funds by the Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Administration (“NCUA”), whichever is applicable. Funds will be deposited within StoneCastle’s network of Insured Depositories (“Deposit Network”). StoneCastle requires $100,000.00 minimum deposit to open a FICA Program account. Clients are advised that a conflict of interest exists if we recommend the FICA Program compared to you using your own financial institution, another financial institution, or another cash management program. INDSQUARE and/or your advisor will earn a fee from StoneCastle which is paid by you if you participate in this program (Please review Item 5 – Fees and Compensation for more information regarding this fee). Your advisor will assist clients in signing up for this program and facilitating the transfer of funds between the client’s like-named accounts. You are under no obligation to act upon any of the recommendations made by your Advisor or by INDSQUARE itself. Please make sure to review StoneCastle Network, LLC’s FICA for advisors account application and Terms and Conditions in its entirety prior to engaging in this activity. Johnson, Kendall, and Johnson Inc. (Hereby referred as “JKJ” or “Company”) INDSQUARE may introduce you to JKJ, a privately owned, independent insurance brokerage firm. Over the last 65-plus years, JKJ has grown to be acknowledged as one of the premier insurance brokerage firms in the United States. JKJ’s capabilities have also expanded throughout the world, giving them a global perspective that they apply to their risk management strategy. JKJ works with clients ranging from Fortune 1000 companies to sole proprietorships to families, but their commitment remains the same. INDSQUARE advisors (hereby referred to as the “Broker”) who refer clients to JKJ warrants and represents that he/she is a duly licensed broker or agent pursuant to the laws of the State wherein Broker is located and wherein it conducts business, and desires to effect and/or continues to effect insurance coverages for its clients through the Company, in accordance with the laws and regulations of any state in which Broker operates. JKJ requires the Broker to maintain Errors and omissions (“E&O”) coverage based on JKJ’s Terms of conditions. INDSQUARE may refer clients seeking commercial, personal, or employee benefits insurance coverage to JKJ. INDSQUARE primarily utilizes the Company for employers seeking to establish group health insurance coverage to provide a best-in-class experience for their employees in addition to reducing the long-term costs of insurance. This arrangement creates a conflict of interest as the Broker receives financial incentives for referring you to the Company. In consideration of similar arrangements with other Insurance Brokerage firms, this commission may be higher or lower than what other insurance brokerage firms may offer for the same type of referral, which could cause the advisor to refer you to the Company over other insurance brokerage firms. Please review Section 5(A) which provides more information regarding the Broker’s commission split. Rocket ProSM TPO 10  INDSQUARE may have some reps who hold a Nationwide Mortgage Licensing System number (“NMLS”) as a Mortgage Loan Originator (“MLO”). The Nationwide Mortgage Licensing System is a centralized online database that mortgage and finance regulatory agencies use to maintain state licensing programs. The database then creates their NMLS numbers, assigning unique identifiers to mortgage loan originators and lending companies. When Congress passed the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (“SAFE Act”), it required states to pass legislation mandating that MLOs be licensed. In addition, the SAFE Act required state agencies to participate in and share licensing information through NMLS. MLOs must complete 20 hours of educational training, pass a national mortgage test, credit report review, and pass an FBI criminal background check to get their license through NMLS. In addition, MLOs must complete 8 hours of continuing education annually to maintain their state license(s). NMLS also has a free, public facing portal (https://NMLSConsumerAccess.org) where anyone can look up any licensed MLO to check their status and credentials. You can see their licenses and where they’re authorized to do business. INDSQUARE advisors who hold an NMLS number may discuss lending products with you. Advisors with an NMLS number can originate Mortgages and some other home loan products. This is accomplished by partnering with Rocket ProSM TPO. The Rocket ProSM TPO application is owned and operated by Rocket Mortgage, LLC, 1050 Woodward Avenue, Detroit, MI 48226. Rocket ProSM TPO provides convenient access to technology, resources, products, and competitive pricing. Advisors who hold an NMLS number may receive additional commissions from Rocket ProSM TPO for their role as an MLO. This may create a conflict of interest for clients, as those advisors will be less likely to refer you to an outside lender in which they will not receive commissions, regardless of whether another lender has lower rates. The Advisor also has a conflict of interest when recommending any refinance of existing loans, as this would generate additional commissions. Commissions generated by this activity are above and beyond any Advisory Fees, Insurance Commissions, or any commissions generated by commissionable securities business. Caribou Health Technologies, Inc. (hereinafter referred to as “Caribou”) INDSQUARE utilizes the services of certain third-party providers that the Adviser believes may offer additional tools or services to assist in providing comprehensive financial planning and advisory services to clients (“Ancillary Services”). These services are not required, may not be offered to all clients, and may not be available through all Investment Adviser Representatives (“IARs”) of INDSQUARE. Examples of Ancillary Services include, but are not limited to, healthcare needs analysis, legal document preparation services, cash management services, insurance brokerage services, cryptocurrency-related products, and mortgage services. Expenses related to healthcare are often uncertain and difficult for individuals to project, particularly around known life events such as retirement or aging. Caribou provides a healthcare cost optimization and planning platform that offers customized analysis of a client’s current and projected healthcare costs. Unlike generic healthcare cost estimators, Caribou’s software is designed to integrate healthcare considerations into broader financial planning, which may assist clients in better understanding and planning for future healthcare needs. 11  If a client’s financial advisor recommends Caribou, the client is not required to utilize Caribou’s services or to purchase health insurance through Caribou. Clients may obtain health insurance coverage through any provider of their choosing. If a financial advisor recommends Caribou and charges a fee for access to or use of this service, the advisor has a financial incentive to do so, which constitutes a conflict of interest. Advisors who utilize Caribou pay an ongoing licensing fee for access to the platform and may be required to commit to a minimum number of client households using the service. These fees are paid by the advisor regardless of whether any particular client chooses to utilize Caribou. In addition, if a client elects to purchase health insurance through Caribou, this may further increase the financial incentive for the advisor to recommend or continue using Caribou, thereby increasing the potential conflict of interest. Since each advisor independently determines their advisory fee structure, subject to maximum amounts permitted, the nature and extent of this conflict may vary by advisor. Clients should carefully consider these conflicts when evaluating whether to utilize Ancillary Services and are encouraged to review Section 5(A) for additional information regarding fees related to these services. Cryptocurrencies (herein referred to as “Digital Assets”) Cryptocurrency is digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Cryptocurrency is a speculative investment and is not currently defined as a security. The speculative nature of cryptocurrencies notwithstanding, Independent Financial Advisors of INDSQUARE may recommend cryptocurrency exposure for diversification purposes in the portfolios of some of our clients. Investments in cryptocurrencies involve substantial risks and are subject to the potential for liquidity constraints, extreme price volatility, and complete loss of principal. Clients who invest in cryptocurrencies should be prepared to bear a substantial or total loss of capital and there can be no assurance that the investment objectives of any client will be achieved. INDSQUARE may also recommend “Cryptocurrency-related products,” which refers to investment securities that either directly purchase cryptocurrencies or are involved in the cryptocurrency space, such as through mining cryptocurrency, investing in companies that develop and use blockchain technology, etc. Certain cryptocurrency- related products that are approved for use, that do not directly invest in cryptocurrencies, can be purchased in a similar manner as other equities within either brokerage, SAM, or SWM accounts. Cryptocurrency-related products that directly invest in or hold cryptocurrencies as underlying holdings are also available for purchase, but they require additional suitability requirements. Although Cryptocurrencies have not been deemed a “security”, Cryptocurrency-related products containing or related to cryptocurrencies (exchange- traded funds, exchange-traded trusts, equities, etc.) could be deemed a security. Please note that not all Cryptocurrency-related products are approved for use. If you are 12  interested in Cryptocurrency related products, please discuss with your advisor which products are available through our unaffiliated third- party Broker/Dealer. INDSQUARE may direct clients of Independent Financial Advisors to HeightZero, LLC ("HZ"), a third- party technology company that is a fully owned subsidiary of BitGo Holdings, Inc. (hereby referred to as “BitGo”). HZ has developed a proprietary turnkey digital asset management software platform that provides financial advisors, and their clients, access to BitGo’s platform to buy and sell blockchain-based, eligible, digital assets through one convenient dashboard (the "HZ TDAMP"). The HZ TDAMP allows trading, account monitoring, portfolio management and rebalancing, development, and execution of different trading strategies, and reporting of customer positions and transactions. HZ provides access to one or more third-parties for various services; including, but not limited to, website hosting, web-based security protection, etc. HZ does not provide Anti- Money Laundering (“AML”) or Customer Identification Program (“CIP”) services, investment advice, and/or tax related services. Custody services are provided by BitGo, subject to a separate custodial service agreement, terms and conditions, privacy policy, or other agreement between BitGo and INDSQUARE or INDSQUARE’s customers. Custody of the digital assets purchased for or by clients will be maintained by BitGo pursuant to the written instructions of each of INDSQUARE’s clients. Custody of any cash deposited by such customers will be held in an account for the benefit of INDSQUARE’s client as provided for by BitGo. Neither HZ nor the HZ TDAMP will take custody of customer cash, funds, or eligible digital assets at any time. Accounts opened at HZ are established by an individual account level agreement. Clients who utilize HZ will be charged additional fees above the stated advisory fees. Clients are advised that a conflict of interest exists when your advisor recommends this provider. HZ provides a platform in which INDSQUARE and its IFAs can charge an ongoing advisory fee for the management of eligible digital assets. The costs associated with HZ and HZ TDAMP may be higher than other platforms. The costs associated with the HZ TDAMP technology, which includes several types of fees, will be passed on to you, the client. These fees will reduce your overall returns. Your advisor’s management fee will not exceed those of our maximum advisory fee stated in Item 5 Fees and Compensation; however, the total costs associated with the management of this account may exceed our maximum advisory fee allowed once all fees are considered for all third-party fees that are passed on to you. Please note that clients can purchase these assets on their own directly through third-party custodians with minimal to no costs. Please review Item 5 – Fees and Compensation for more information regarding these fees that were discussed. Clients should discuss with their advisor alternative options in which the advisor may consult on digital assets that are held by the client at third-party custodians. Assets, in which the advisor consults on, may be considered an asset under advisement vs. regulatory assets under management. The costs associated with consulting on assets held by third-party custodians may reduce your overall costs by eliminating third-party platform fees. Under consulting arrangements, the client is free to accept or reject any recommendation from your advisor, and the client acknowledges that they have the sole authority regarding the implementation, acceptance, or rejection of any recommendation or advice from their advisor. For more information on these services, please review the Financial Planning and Consulting section of this disclosure. Self-Directed Brokerage Accounts (“SDBA”) 13  A self-directed brokerage account (“Self-Directed account”) is an account created by a participant (i.e. the client) of an employer sponsored plan which is then held by the plan administrator, but the participant has, in effect, their own brokerage account in which all transactions are made at their direction. Not all retirement plans permit SDBA programs. SDBA allows the participant to direct the investments in the account or in some cases, to appoint an adviser. Assets held in the SDBA are considered plan assets under ERISA but are not supervised or reviewed by the plan fiduciaries. INDSQUARE may refer clients to third parties to offer advisory services within SDBA programs. INDSQUARE may also act as the Investment Adviser to offer SDBA advisory services through plan sponsors, such as fidelity. Fidelity offers plan participants this service through Fidelity’s BrokerageLink program, in which the participant either directs the investments in the account themselves or they can assign an adviser to their SDBA. In situations where INDSQUARE refers advisory business to a third-party, INDSQUARE will refer SDBA business to either The Pacific Financial Group Inc. (“TPFG”) and/or Absolute Capital Management, LLC. INDSQUARE has no financial benefit in referring advisory business to one of these advisers over the other based on the referral fee paid to INDSQUARE and/or our IARs. INDSQUARE may refer business to one or the other adviser based on agreements that the third-party adviser may have with the plan sponsor for your employer sponsored plan. Although INDSQUARE may not have a conflict of interest between which adviser receives the advisory business based on the referral fee, there could still be a conflict of interest based on business entertainment or gifting. INDSQUARE reduces this conflict of interest by complying with federal regulations to limit potential improprieties among IARS and third parties. In addition to the noted conflict of interest, other conflicts may exist. Among these conflicts is that INDSQUARE and its IARs will receive a referral fee from the third-party adviser. By receiving this compensation, your advisor has a direct financial benefit in you hiring a third party, which will increase your total costs within your employer sponsored plan, and in some cases, these fees can be substantial. For additional fee information please review Item 5 – Fees and Compensation under the Third-Party Adviser fees and the SDBA section. C. Client-Tailored Services and Client-Imposed Restrictions INDSQUARE tailors a program for each individual client. This program will typically include an interview session to get to know your specific needs and requirements and may also include a more formalized plan that will be executed by us on your behalf. You may impose restrictions on investing in certain securities or types of securities in accordance with your values or beliefs. These requests must be made in writing and if the restrictions prevent us from properly servicing your account or would require us to deviate from our standard suite of services, we reserve the right to end our relationship with you. D. Wrap Fee Programs INDSQUARE provides investment management services as the sponsor and manager of the Independence Square Advisors Wrap Program (the “Wrap Program”). Accounts in the Wrap Program are charged a single, bundled (“wrap”) fee for investment advice, brokerage services, administrative expenses, and other fees and expenses. INDSQUARE receives a portion of the wrap fee for its investment management services and participants in the 14  Wrap Program may pay a higher aggregate fee than if investment management and brokerage services are purchased separately. Additional information about the Wrap Program is available in our Wrap Brochure, which appears as Part 2A Appendix 1 of our Form ADV. E. Assets Under Management As of March 4, 2026, INDSQUARE had $1,833,229,303 in regulatory assets under management, all of which are managed on a discretionary basis. As of March 4, 2026, INDSQUARE had $749,522 in regulatory assets under management managed on a non-discretionary basis. As of March 4, 2026 INDSQUARE had $125,688,888 in assets under advisement. Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees INDSQUARE charges a fee as compensation for managing your account. This advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period and is subject to the following maximums: Total Assets Under Management Maximum Annual Fee All Assets Up to 2.50% Advisory and consulting fees are generally negotiable, and the applicable fee schedule will be set forth in the client’s Investment Advisory Agreement or Financial Planning and Consulting Agreement. Client may terminate this Agreement without penalty by providing written notice to Adviser within five (5) business days of executing this Agreement. Upon such termination, all asset-based advisory fees paid in advance shall be refunded in full. Financial Planning and Consulting fees, including hourly fees, shall remain payable to the extent services have been performed or hours have been incurred prior to termination. Adviser may retain or invoice for such earned fees based on the applicable fee arrangement. This five-day cancellation right shall not apply to services already completed, work in progress, or hours incurred under the Financial Planning and Consulting section prior to termination. Thereafter, either agreement may be terminated at any time upon written notice. At our discretion, we may add (aggregate) asset amounts in accounts from your same household together to determine the advisory fee for all your accounts. We may do this, for example, where we also service accounts on behalf of your minor children, individual and joint accounts for a spouse, and/or other types of related accounts. This consolidation practice is designed to allow you to benefit from an increased asset total, which could potentially cause your account(s) to be assessed with a reduced advisory 15  fee. Private Fund Management Services INDSQUARE does not receive compensation in connection with the management of any Private Funds. Compensation for the management of Private Funds is received by ISQ Capital LLC, an affiliated investment adviser under the common ownership of ISQ Holdings Ltd., and typically consists of an asset-based management fee and, in certain cases, a performance-based allocation or fee, as permitted under applicable law. Fee structures, expense allocations, liquidity terms, and withdrawal rights are described in the applicable offering and governing documents of each Private Fund. Certain investors may be subject to different fee arrangements or terms, including fee reductions or waivers. The management of Private Funds by ISQ Capital LLC may give rise to conflicts of interest, including those related to proprietary product sponsorship, ownership interests of management personnel, performance-based compensation, allocation of investment opportunities, side-by-side management of accounts, and differing fee structures among clients. While INDSQUARE does not act as the investment manager to the Private Funds, certain members of INDSQUARE’s executive management team are also principals and owners of the Private Funds and serve in advisory or management capacities through ISQ Capital LLC. These affiliations present potential conflicts of interest, which are disclosed and managed in accordance with ISQ Capital LLC’s fiduciary obligations and compliance policies. Additional information regarding such conflicts is provided elsewhere in this Brochure and in the applicable Private Fund offering documents. Retirement Plan Participant Advisory Services (ERISA Accounts) Participants who elect to engage the Adviser for these services pay an advisory fee, which is disclosed prior to engagement. The maximum advisory fee for this service is 1.00% annually, calculated based on the assets within the participant’s retirement account that are subject to advisory services. The actual fee charged may be less than the maximum and may vary depending on the IAR providing the service. Advisory fees are paid by the participant and are separate from and in addition to fees and expenses imposed by the retirement plan itself, including but not limited to plan administrative fees, recordkeeping fees, custodial fees, and the internal expenses of the plan’s investment options. The receipt of advisory fees from participants creates a conflict of interest, as the Adviser and its IARs benefit financially when a participant elects to engage advisory services. In addition, IARs who offer this service may have an incentive to recommend advisory services rather than a participant managing their account independently. The Adviser seeks to mitigate these conflicts by acting in accordance with its fiduciary obligations under ERISA, providing full and fair disclosure of fees, services, and limitations, and emphasizing that participants retain full discretion over all investment decisions and are not required to engage the Adviser. The Adviser does not receive compensation from plan sponsors, recordkeepers, or investment product providers in connection with this service, unless otherwise disclosed. 16  Third-Party Adviser Fees We receive our standard fee on top of fees paid to third-party advisers. The third-party advisers we currently have the discretion to choose from are: AssetMark, SEI, Haverford Trust, The Pacific Financial Group Inc., and Absolute Capital Management LLC. If applicable, this relationship is memorialized in a contract between INDSQUARE, and each third-party adviser and the combined fees will not exceed any limit imposed by any regulatory agency. We negotiate our fee with each third-party adviser and the third-party adviser will disclose to you all fees that they have paid to INDSQUARE, as well as the terms of the compensation arrangement. Under SDBA programs, INDSQUARE will refer SDBA business to either The Pacific Financial Group Inc. (“TPFG”) and/or Absolute Capital Management, LLC (“Absolute Capital”). INDSQUARE has adopted a max referral fee of 0.75% on all SDBA programs. This does not reduce INDSQUARE’s Max advisory fee on all other previously stated categories other than utilizing third-party advisers for the purpose of SDBA programs. This max referral fee is to reduce the conflict of interest between selecting TPFG or Absolute Capital over the other. This Max referral fee is in no way your total costs. Each Investment adviser charges their own fees based on their own fee structures. You are encouraged to review all third-party documents and disclosures to fully understand the total fees which you will incur by utilizing the third- party. Outside of the referral fee, INDSQUARE receives no additional direct compensation from these third parties. In some cases, INDSQUARE may receive noncash compensation in the form of gifts and/ or business entertainment. INDSQUARE complies with all federal regulations pertaining to gift and entertainment standards to not only stay compliant, but also to reduce conflicts of interests for our IARs during their selection process. For more information regarding conflicts of interests on SDBAs, please see Item 4 – Advisory Business, SDBA programs. Wealth Inc. (“Wealth.com”) Wealth Inc. charges each financial advisor who chooses to offer this service as an ongoing licensing fee for access to the Wealth.com platform. If your advisor chooses to engage the services of the Wealth.com platform, your financial advisor will pay this licensing fee regardless of if you choose to use this service or not. Your advisor may charge you to be able to access this website and their templated estate planning documents. The fees associated with the utilization of the Wealth.com platform will vary among financial advisors. Some financial advisors may choose to charge a one-time access fee for the initial creation of these templates, while some advisors may choose to charge an ongoing monthly fee for access to these documents. If your advisor chooses to charge a one-time fee, this fee should not exceed $2,400.00 for access to the full suite of the Wealth.com platform for the initial creation of these templates, which currently includes 5 templates. If your advisor chooses to charge monthly for access to this suite of templated documents, the monthly charge should not exceed $200.00 per month, paid 1 month in advance. In some cases, your financial advisor may choose not to charge for this service, in these cases the advisor may treat it as a value-added service to his/her clients. In either case, you should discuss the fees with your advisor prior to engaging in this service. In the cases in which your advisor charges for access to this service, your financial advisor has a conflict of interest in recommending you to this third-party, since he/she will 17  financially benefit from you utilizing this service. The Wealth.com platform may allow for some additional add-on services which may include separate charges by third-party, unaffiliated attorneys. These add-on services are above the use of templated documents and are not included in the costs associated with INDSQUARE, LLC. Please review Section 4(B) for more information on conflicts of interest and some additional information regarding this service. Please review all the information provided by the Wealth.com platform prior to engaging in their services as there may be some additional information not previously covered in this disclosure. Cash Management Services Clients who utilize the FICA For Advisors cash management program (“FICA Program”) offered by StoneCastle Network, LLC (“StoneCastle”), an affiliate of StoneCastle Cash Management, LLC will pay a referral fee of 0.25% per year, which will be deducted monthly. For as long as you have a FICA Account relationship with StoneCastle, StoneCastle may continue to deduct this fee to pay INDSQUARE, and its IARs, annually as a continuous referral fee. This fee covers any expenses for introductory efforts, as well as, including, but not limited to, the expenses of any ongoing, client consultations. In no event will the services include providing cash management services on behalf of StoneCastle in any manner. StoneCastle Network, LLC, charges additional fees, referred to as FICA Fees. The FICA Fee will be determined by StoneCastle and will be deducted from your FICA Account on the date on which interest from an Insured Depository is credited to your FICA Account. INDSQUARE does not receive any portion of the FICA Fee, therefore, please review StoneCastle Network, LLC’s account application and terms and conditions to learn more about these fees. Johnson, Kendall, and Johnson Inc. (Hereby referred as “JKJ” or “Company”) JKJ charges fees above the normal cost of insurance. INDSQUARE (“Broker”) has no control over the costs associated with the services provided by the Company. The Company’s prices vary depending on each client’s situation, but prior to engaging in their services, JKJ will provide you with a Broker Compensation Disclosure as required under section 202 of the Consolidated Appropriations Act, 2021 (“CAA”). The Company may earn additional compensation from insurers, vendors, or other third parties that cannot be calculated as of the time this disclosure is made to you, or prior to the date JKJ executed, extended, or renewed contract with you is effective. For example, JKJ may receive additional compensation contingent upon certain conditions being met, including, but not limited to, profitability, growth, churn/retention, or the volume of services provided. Compensation may be in the form of additional commissions, bonuses, or benefits (“compensation”). Furthermore, JKJ may receive corporate sponsorships for webinars, training, or other programming they provide for you and other clients, or for their own internal training. Whether JKJ receives any of the above-mentioned compensation, or how much that compensation may be, cannot be discerned at this time. Should you have any questions about any of the information provided on the Broker Compensation Disclosure document, please don’t hesitate to contact your Account Manager at JKJ to discuss your questions. Please make sure you fully understand all the costs and charges prior to enlisting JKJ’s services. In consideration for the acceptance of 18  insurance business from the Broker, the Company shall pay the Broker a commission for the Financial Benefit received by the Company based on the commission table below. For the purposes of this Agreement, “Financial Benefit” shall include the total of all commission and/or fee payments received by the Company in a calendar month, for a client of Broker that is placed by the Broker with or through the Company. This arrangement creates a conflict of interest as the Broker receives financial incentives for referring you to the Company. Please review Section 4(B) for more information regarding this activity including more details around the conflict of interests that this activity may create. Rocket ProSM TPO INDSQUARE Advisors may hold an NMLS number allowing them to act as an MLO through Rocket ProSM TPO. The costs associated with this activity may change from time-to-time, but if you are closing on a Mortgage, the costs will be disclosed to you at least 3 days prior to closing within the mandatory “closing disclosure” document. In the case of other types of home loans, the costs will be disclosed prior to closing. Typical costs associated with home loan products may include application fees, mortgage insurance fees, appraisal fees, title insurance and title search fees, credit report fees, origination fees, home inspection costs, attorney or notary signing agent fees, settlement fees, inactivity fees, transactional fees, early termination fees (Not applicable in PA), annual fees, estimated property taxes, estimated homeowner insurance, etc. Regarding the Advisor’s compensation, the advisor’s compensation will vary based on the type of loan product used. If you wish to know how the advisor is paid, please discuss this with your advisor prior to engaging in this activity. Please review section 4(B) for more information regarding this activity as well as conflicts of interest. Caribou Health Technologies, Inc. Once an analysis is complete, your advisor may be licensed to sell you insurance products, and if so, your advisor may receive additional remuneration above the costs of the analysis through commissions by selling you the insurance product to implement the analysis. Not all advisors are licensed to sell health insurance, and/or the advisor may not incorporate health insurance into his/her practice, in these cases, you may have to find a third-party provider which offers such services. This too would include additional costs for the purchase of an insurance policy through a third-party provider. Clients are responsible for payment of Ancillary Services’ costs. The costs may vary based on the advisor offering the Ancillary Service and/or each client’s overall assets under INDSQUARE’s management. Advisors may, in their sole discretion, directly pay certain 19  Ancillary Services’ expenses from management fees collected or may reimburse clients through fee rebates for some or all of the costs associated with these Ancillary Services. INDSQUARE and/or your advisor may receive remuneration or benefit for referring clients to Ancillary Service providers, including, but not limited to, Caribou Health Technologies, Inc. If you choose to use Caribou Health Technologies, Inc., your advisor may charge up to $750 for access to this software for 12 months (maximum fee allowed for this service). During the 12 months, you may re-run the analysis with different variables as many times as you would like. After the 12 months expires, if you access your Caribou account, it will automatically renew your subscription for the following 12 months, causing you to be billed again, at the same rate as your initial fee, for the subsequent 12 months. Some advisors may charge this fee as lump sum annual fee, billed at the time of access to the software, while some advisors may charge a monthly fee (up to the annual maximum), while other advisors may not charge a fee at all and may only provide this service as a value-added to his/her clients. Prior to utilizing this service, please discuss the fees with your financial advisor and make sure you fully understand the costs. If your financial advisor recommends Caribou, and if your advisor is charging you for this service, he/she will have a financial incentive for doing so, which would be a conflict of interest. Your financial advisor is paying an ongoing licensing fee for access to Caribou’s platform, and your advisor must commit to a minimum number of households that will use said service, which in turn increases your advisor’s costs for offering this service. Your financial advisor will pay this fee regardless of whether you utilize this service or not. Since each advisor determines their fee structure, up to the maximum amount allowed, the presence of a conflict of interest may be different for each advisor. Regardless, it is important to know that if your financial advisor is charging for this service, your financial advisor has a financial incentive to recommend that you utilize this service provider. Please review section 4(B) for additional information regarding this service. Digital Assets Digital assets purchased through HeightZero, LLC and the HZ TDAMP platform will incur platform service fees that are passed on to you, the client. INDSQUARE pays HZ platform service fees as a percentage-based fee in an amount equal to 0.0834% (8.34 basis points) per month, which is the equivalent of 1.00% per year, rounded to the nearest 100th of a percent, of the Weighted Average Value of each Eligible Digital Asset held in customer accounts being managed by INDSQUARE during that calendar month. The platform service fee charged to INDSQUARE by HZ is inclusive of custody fees assessed by BitGo custodial services through the HZ TDAMP. The above-mentioned platform service fee charged to INDSQUARE will be passed on to you, the client, as a third-party fee which is not included in your advisory fee. The HZ TDAMP provides connections to BitGo’s trading Platform for digital assets. The BitGo trading platform may charge standard transaction fees on a per-trade basis. Certain basic orders may not be subject to any transaction fees. Any transaction fees will be incorporated into the order execution process flow and any order from an account with insufficient assets to pay the associated transaction fee will be rejected. HeightZero may 20  receive technology service fees from BitGo’s trading platform on a periodic basis and will disclose any such fees received to INDSQUARE. INDSQUARE also provides Financial Planning and Consulting services; please refer to the Financial Planning and Consulting section of this disclosure document for more information. Under this service, an Independent Financial Advisor of INDSQUARE may provide consulting services pertaining to digital assets for a fee. This allows the asset to remain at its current custodian while still receiving advice. Assets under a financial planning and consulting agreement are not assets in which we manage, nor do we have any trading authority. You are under no obligation to act upon the advice of your advisor. If you want to implement the advice of your advisor, it is your responsibility to implement the changes to your portfolio. Assets for which we consult, but do not manage, are assets in which we have no discretionary trading or decision-making capabilities as it is not an asset under our management. Please review the Financial Planning and Consulting agreement in detail prior to entering into a Financial Planning consulting arrangement. The costs related to these services may be found under the financial planning and consulting arrangements below. Pension Consulting Services Fees The advisory fee is calculated using the value of the assets on the last business day of the prior billing period. These fees are generally negotiable and the final fee schedule, which is subject to the maximum listed below, will be memorialized in your advisory agreement. Total Assets Under Management Maximum Annual Fee Up to 2.50% All Assets You may terminate this Agreement without penalty by providing written notice to Adviser within five (5) business days of executing this Agreement. Upon such termination, all asset-based advisory fees paid in advance shall be refunded in full. Thereafter, you may terminate the pension consulting agreement immediately upon written notice. Fixed Fees The rate for creating client pension consulting plans is up to $100,000 and the final fee schedule will be memorialized in the advisory agreement that you sign. This service may be canceled immediately upon written notice. Financial Planning and Consulting Fees Fixed Fees The fixed fee for initial financial planning services is up to $20,000 and depends upon the complexity and scope of the plan, the client’s financial situation, and objectives. In the case that we agree to provide ongoing consulting services, the maximum flat 21  consulting fee will be $10,000 per month ($30,000 per quarter, if billed on a quarterly basis). Hourly Fees The negotiated hourly fee for these services is up to $2,000 per hour. You may terminate the Agreement at any time upon written notice. If an Agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to you, as appropriate. Use of Margin INDSQUARE may be authorized to use margin in the management of your investment portfolio. In these cases, our investment advisory fee will not be charged on any margin debit balance, but rather only on the net equity of the balance. Margin interest, however, will be charged in addition to the investment advisory fee. B. Payment of Fees As described below, INDSQUARE may bill advisory and consulting fees either in advance or in arrears, as set forth in the applicable Investment Advisory Agreement or Financial Planning and Consulting Agreement executed by the client. Under no circumstances will advance fees exceed $1,200, nor will any fee be collected more than six months in advance. Portfolio Management Fees Asset-based portfolio management fees may be billed in advance or in arrears, as specified in the client’s Investment Advisory Agreement. With the client’s written authorization, portfolio management fees may be deducted directly from the client’s account on a quarterly basis. Alternatively, fees may be invoiced and billed directly to the client on a quarterly basis. Pension Consulting Fees Asset-based pension consultancy fees may be billed in advance or in arrears, as specified in the applicable agreement, and, with the client’s written authorization, may be deducted directly from the client’s account on a quarterly basis. Fixed pension consulting fees are generally billed pursuant to the terms of the applicable consulting agreement. Unless otherwise agreed, fixed pension consulting fees are typically billed 25% in advance, with the remaining balance due upon presentation or delivery of the plan. Third-Party Adviser Fees 22  The timing, frequency, and method of payment for fees associated with the selection or use of third-party investment advisers or managers will depend on the specific third-party adviser selected. Such fee arrangements will be disclosed to the client prior to entering into a relationship with the third-party adviser. Financial Planning and Consulting Fees Financial planning and consulting fees may be billed in advance or in arrears, as set forth in the Financial Planning and Consulting Agreement executed by the client. Fees may be paid by check, wire, or other approved method. Fixed financial planning fees may be billed up to 100% in advance, subject to the six-month advance payment limitation. Hourly financial planning fees are billed in accordance with the fee schedule and billing terms agreed upon in the Financial Planning and Consulting Agreement and may be required to be paid in advance based on a reasonable estimate of the time required to complete the engagement. Ancillary Services, Platform Fees, and Other Third-Party Charges In addition to advisory and consulting fees paid directly to INDSQUARE, clients may incur fees and expenses charged by third-party providers in connection with Ancillary Services, platform access, insurance brokerage services, cash management programs, digital asset platforms, mortgage services, or other non-investment advisory offerings described elsewhere in this brochure. Fees charged by third-party providers are separate from and in addition to the fees paid to INDSQUARE and are generally paid directly to the applicable third party or deducted by such provider pursuant to its own billing practices and disclosures. The timing, frequency, and method of payment for third-party fees are determined by the applicable provider and are disclosed to clients prior to engagement. INDSQUARE does not control the fees charged by third parties and does not receive any portion of such fees unless expressly disclosed. In certain cases, INDSQUARE or its Investment Adviser Representatives may receive referral fees, commissions, licensing cost reimbursements, or other compensation, including non-cash compensation, in connection with a client’s use of third-party services. These arrangements create conflicts of interest and are disclosed in the applicable sections of this brochure. Examples of third-party fees that may be incurred include, but are not limited to: Insurance premiums, commissions, and related brokerage compensation - - Platform access or licensing fees (e.g., estate planning, healthcare analysis, or digital asset platforms) - Cash management program fees and referral fees - Digital asset platform service fees, custody fees, and transaction fees - Mortgage origination fees and related loan costs 23  - Fees charged by unaffiliated attorneys or other professionals Clients are responsible for all third-party fees unless otherwise disclosed. Clients are encouraged to review all third-party agreements and disclosures carefully to fully understand the total costs associated with these services. C. Additional Fees and Expenses Advisory fees payable to us do not include other fees you may pay when we purchase or sell securities for your account(s) and you can find more information in the “Brokerage Practices” section of this Brochure. The following non-exhaustive list details some of the fees or expenses that you may pay directly to third parties, whether a security is being purchased, sold, or held in your account(s) under our management: • Brokerage commissions; and or • Transaction fees; and or • Exchange fees; and or • SEC fees; and or • Advisory fees and administrative fees charged by mutual funds and/or exchange traded funds; and or • Advisory fees charged by sub-advisers (if any are used for your account); and or • Custodial fees; and or • Deferred sales charges (on mutual funds or annuities); and or • Odd-lot differentials; and or • Transfer taxes or fees; and or • Wire transfer and electronic fund processing fees; and or • Fees on existing variable annuities that may have been subject to trailing service fees, deferred sales charges, mortality and expense fees; and or • Fees on mutual fund assets held in your account that may have been subject to deferred sales charges, 12b-1 or shareholder servicing fees, administrative fees, and other mutual fund annual expenses as described in the fund’s prospectus. Our investment advisory accounts may be custodied with LPL Financial via a SWM account. When utilizing a SWM account, you will have the option to bear all transaction charges or you can have them borne by the Adviser for any purchases, sales, and exchanges in the account, including for mutual funds, equities, fixed income securities, and options as in the case with WRAP accounts. When mutual funds within SWM accounts charge 12b-1 fees (typically Class A shares), clients bear those fees regardless. Transaction charges vary based on security type (see the SWM agreement for more information) and in the case of mutual funds, the transaction charges vary depending on whether LPL retains compensation from the mutual fund and therefore assesses a lower transaction charge. Transaction charges are thus typically higher for mutual funds with lower expense ratios. 24  Our representatives may adjust the advisory fee charged on assets in a SWM account to offset the transaction charges they absorb on behalf of you, particularly when they select lower expense mutual funds for your account. According to LPL Financial’s SWM agreement: “Transaction charges are paid to LPL to defray costs associated with trade execution; however, they are not directly related to transaction-related expenses of LPL and are a source of revenue to LPL.” D. Refunds of Prepaid Fees INDSQUARE collects fees in advance or in arrears. Refunds required for fees paid in advance, but not yet earned, will be refunded on a prorated basis and returned within fourteen (14) days to you either via check or return deposit back into your account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period, up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. For hourly fees that are collected in advance, the fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the date of termination. INDSQUARE has no ability to refund third-party fees. Any refund requested from a third- party is subject to the third party’s discretion and/or client agreement. Fees that are billed and paid in arrears represent compensation for advisory or consulting services already provided and, accordingly, are not refundable. E. Outside Compensation for the Sale of Securities to Clients Independence Square Holdings, LLC (“INDSQUARE”) is a registered investment adviser whose Investment Adviser Representatives (“IARs”) may also be dually registered as registered representatives of LPL Financial LLC (“LPL”), a registered investment adviser, Member FINRA/SIPC. When acting in their capacity as registered representatives of LPL, such individuals may receive transaction-based compensation, including commissions, sales charges, trails, or other remuneration, in connection with the sale or placement of securities through LPL. In addition, INDSQUARE may receive compensation related to brokerage activity, including overrides or other forms of revenue sharing based on, or derived from, commissions or other transaction-based compensation generated by its dually registered representatives through LPL. Any such brokerage-related compensation is separate from, and in addition to, the advisory fees clients pay to INDSQUARE for investment advisory services. Advisory fees charged by INDSQUARE are not reduced or offset by commissions, overrides, or other brokerage-related compensation. 25  INDSQUARE and/or its IARs may also receive compensation in connection with referrals to unaffiliated third-party investment advisers, platform sponsors, or service providers in limited circumstances, including when clients elect to engage advisory or investment services through self-directed brokerage account (“SDBA”) programs or similar arrangements. In such cases, INDSQUARE or its IARs may receive referral fees or other compensation from the third-party adviser or provider. Referral compensation does not reduce the fees charged by the third-party adviser and generally increases the overall cost to the client. These arrangements create a conflict of interest because INDSQUARE and its IARs have a financial incentive to refer clients to advisers or providers that provide such compensation. Clients are not required to engage any recommended third-party adviser or service provider. including annuities and other In addition, certain IARs of INDSQUARE may be licensed as insurance agents and, when acting in that capacity, may receive commissions or other compensation for the sale of insurance-related products. insurance products, Compensation received in connection with insurance or annuity transactions is separate from, and in addition to, advisory fees paid to INDSQUARE. Clients are under no obligation to purchase insurance or annuity products through any IAR of INDSQUARE and may obtain such products through other providers of their choice. INDSQUARE does not supervise brokerage or insurance activities in its capacity as a registered investment adviser. Brokerage activities conducted through LPL, including securities transactions and insurance products offered through LPL, are subject to LPL’s supervisory authority, policies, procedures, and regulatory oversight, including LPL’s Advisor Compliance Manual and written supervisory procedures. INDSQUARE’s Chief Compliance Officer also serves, in a separate and distinct capacity, as an Office of Supervisory Jurisdiction (“OSJ”) principal of LPL. In that role, and solely pursuant to LPL’s supervisory structure, the OSJ principal provides supervisory oversight insurance activities conducted through LPL by registered of brokerage and representatives assigned to the OSJ. All INDSQUARE IARs who are dually registered with LPL fall under this OSJ for purposes of LPL supervision. Although the OSJ principal is an employee of INDSQUARE, any supervisory authority exercised in this role is performed on behalf of LPL and remains governed by LPL’s broker-dealer oversight framework and regulatory obligations. Insurance activities conducted outside of LPL, including fixed insurance products offered as an approved outside business activity, are not supervised by INDSQUARE and are instead governed by the applicable insurance carrier, general agency, or other supervising entity, as well as applicable state insurance laws and regulations. Conflicts of interest related to advisory fees, transaction-based compensation (including commissions and overrides), referral arrangements, insurance and annuity sales, ancillary services, and outside business activities are disclosed throughout this Brochure and in applicable client agreements. Clients are under no obligation to implement any recommendation or to utilize any brokerage service, insurance product, ancillary service, or third-party adviser recommended by INDSQUARE or its IARs. 26  F. Conflicts of Interest Involving Fees Independence Square Holdings, LLC (“INDSQUARE”) and its Investment Adviser Representatives (“IARs”) receive compensation for providing investment advisory and consulting services. In addition, certain IARs may receive compensation from sources other than advisory fees, including transaction-based compensation, insurance commissions, referral fees, revenue sharing or overrides, and compensation associated with proprietary or affiliated investment products. These compensation arrangements create conflicts of interest because INDSQUARE and its IARs have a financial incentive to recommend certain products, services, or arrangements that result in additional or higher compensation. Fees, Brokerage Compensation, and Insurance-Related Advisory Compensation Certain IARs of INDSQUARE are dually registered as registered representatives of LPL Financial LLC, a registered investment adviser, member FINRA/SIPC., and may receive transaction-based compensation in that capacity. Such compensation may include commissions, sales charges, asset-based sales charges, trails, service fees, or other remuneration in connection with the sale of securities, including mutual funds and other investment products. In addition, certain IARs of INDSQUARE may be licensed as insurance agents and, when acting in that capacity, may receive commissions or other compensation for the sale of insurance products, including annuities and other insurance-related products. Advisory fees charged by INDSQUARE are not reduced or offset by brokerage commissions, markups, markdowns, spreads, insurance commissions, overrides, or other product-related compensation. As a result, IARs have an incentive to recommend brokerage or insurance products, or advisory arrangements that provide additional compensation rather than alternatives that do not, even when a recommendation is consistent with a client’s objectives. INDSQUARE does not monitor, negotiate, or compare the fees charged by broker-dealers, insurance carriers, or other third-party product sponsors to the advisory fees charged by INDSQUARE. Clients may incur additional fees and expenses in connection with brokerage or insurance products that are separate from, and in addition to, advisory fees paid to INDSQUARE. Performance-Based Fees and Proprietary or Affiliated Investment Products INDSQUARE does not act as the investment manager to private investment funds; however, INDSQUARE is affiliated with ISQ Capital LLC, which sponsors and manages certain privately offered investment funds (each, a “Proprietary or Affiliated Fund”). Certain principals or executive management personnel of INDSQUARE may have ownership interests in, or advisory roles with respect to, such funds through their affiliation with ISQ Capital LLC. When an IAR of INDSQUARE recommends an affiliated or proprietary investment product 27  managed by ISQ Capital LLC, INDSQUARE and its affiliates have a financial interest in the client’s investment due to management fees and, in certain cases, performance-based compensation received by the affiliated adviser. These arrangements create conflicts of interest because there is an incentive to recommend affiliated or proprietary products over other investment opportunities and, where performance-based fees apply, to pursue investment strategies involving a higher degree of risk. Clients are not required to invest in any affiliated or proprietary investment product. All material terms, risks, and conflicts associated with such investments, including performance-based fee arrangements, are disclosed in the applicable offering and governing documents. Third-Party Adviser Referrals, SDBA Programs, and Platform Relationships INDSQUARE and/or its IARs may receive referral fees or other compensation for referring clients to unaffiliated third-party investment advisers, including advisers providing services through self-directed brokerage account (“SDBA”) programs, as well as to third- party cash management providers or other service platforms. Referral compensation generally does not reduce the fees charged by the third-party provider and typically increases the overall cost to the client. INDSQUARE and its IARs may also incur licensing, platform, or access costs associated with third-party technology or service providers used in connection with financial planning, consulting, healthcare analysis, estate planning tools, digital asset platforms, or similar services. In some cases, IARs may charge clients fixed, hourly, or asset-based fees for services that include access to these platforms, which creates an incentive to recommend such services. Clients are not required to engage any recommended third-party adviser, platform provider, or service arrangement and may select alternative providers. ERISA, Retirement Plan, and Participant-Level Services INDSQUARE provides advisory and consulting services to retirement plans and plan participants and may receive advisory fees from participants who elect to engage INDSQUARE. This creates a conflict of interest because INDSQUARE benefits financially when a participant elects advisory services rather than managing their account independently. In addition, where SDBA arrangements involve third-party advisers, INDSQUARE or its IARs may receive referral compensation in connection with those relationships. Side-by-Side Management and Differences in Fee Structures INDSQUARE and its affiliated advisers manage multiple client accounts and investment arrangements that may differ in strategy, liquidity, and fee structure. Some clients pay higher fees than others based on factors such as account size, service complexity, investment strategy, or account type. Accounts that generate brokerage commissions, overrides, referral compensation, or affiliated management fees may create incentives to allocate time, attention, or opportunities differently. 28  These differences create conflicts of interest, including with respect to trade allocation, access to investment opportunities, and the allocation of time and resources among clients. INDSQUARE seeks to address these conflicts through disclosure and through written policies and procedures designed to promote fair and equitable treatment of clients. Disclosure and Oversight of Fee-Related Conflicts INDSQUARE addresses fee-related and compensation-related conflicts primarily through disclosure in this Brochure, applicable offering documents, and client agreements. INDSQUARE also periodically evaluates the overall cost to clients associated with its advisory services. However, INDSQUARE does not monitor, negotiate, or compare the fees charged by third-party product sponsors, broker-dealers, custodians, insurance providers, or service platforms to the fees charged by INDSQUARE for investment advisory services. Clients should carefully consider all fees, costs, and conflicts of interest when evaluating INDSQUARE’s services and any recommended products, arrangements, or service providers, including by reviewing all applicable third-party disclosures and agreements. Item 6: Performance-Based Fees and Side-By-Side Management Beginning March 2025, certain clients of Independence Square Holdings, LLC (“INDSQUARE”) who meet the definition of a “qualified client” under Rule 205-3 of the Investment Advisers Act of 1940 may be eligible to enter into advisory arrangements or invest in investment vehicles that include performance-based compensation. Rule 205-3 provides an exemption from the general prohibition on charging performance-based fees for clients who satisfy specified financial thresholds, including an assets-under- management test and/or a net-worth test, as determined at the time the applicable arrangement is entered. Performance-based compensation may be earned by INDSQUARE directly in connection with certain negotiated advisory arrangements or investment vehicles offered on a one- on-one basis and may also be earned indirectly through investments in privately offered investment funds managed by ISQ Capital LLC, an affiliated investment adviser under common ownership with INDSQUARE (the “ISQ Private Funds”). INDSQUARE does not act as the investment manager to the ISQ Private Funds. In addition, certain executive management personnel of INDSQUARE also serve in advisory, management, and ownership capacities with respect to the ISQ Private Funds. As a result, these individuals may participate in the management of the ISQ Private Funds through the affiliated adviser while also holding ownership interests in such funds. These Private Funds are proprietary investment products of the affiliated adviser. Performance-based fees are not charged in connection with INDSQUARE’s wrap fee program, model portfolios (including Stratavest models), or standard discretionary advisory programs. Any performance-based compensation arrangement—whether offered directly by INDSQUARE or through affiliated investment vehicles—is offered only on a negotiated, individualized basis and requires the client’s informed consent prior to entering into the arrangement or making an investment. 29  All performance-based compensation, including the amount of the fee, the method of calculation, and the timing of when such fees are earned, is fully disclosed in the applicable advisory agreements, private placement memorandum, subscription documents, and other governing documents. The structure and rate of performance- based compensation may vary by product or arrangement. The receipt of performance-based compensation creates conflicts of interest because INDSQUARE, its affiliates, and certain executive management personnel may receive increased compensation when investments perform well. In addition, because certain Private Funds are proprietary products managed by an affiliated adviser and are owned in part by certain INDSQUARE executives, INDSQUARE and its associated persons have a financial incentive to recommend affiliated investment products over non-affiliated alternatives and, in some cases, to recommend investments involving a higher degree of risk. INDSQUARE seeks to mitigate these conflicts through disclosure in this Brochure, additional disclosures in applicable advisory and offering documents, and the adoption and enforcement of written policies and procedures designed to address conflicts of interest and promote fair and equitable treatment of clients. Side-By-Side Management of Multiple Portfolios in performance-based arrangements may INDSQUARE provides investment advisory services to multiple clients concurrently and may recommend or oversee accounts and investment arrangements that differ in investment strategy, liquidity, restrictions, and fee structure. INDSQUARE clients participating invest alongside other INDSQUARE advisory clients and alongside clients of affiliated advisers, including ISQ Capital LLC. The ISQ Private Funds are managed alongside other advisory accounts and investment vehicles, which may give rise to side-by-side management conflicts, including conflicts related to the allocation of investment opportunities, timing of trades, differences in liquidity terms, and differing fee structures. Based on a client’s investment objectives and subject to applicable restrictions, an Investment Adviser Representative (“IAR”) may allocate all or a portion of a discretionary client’s assets to proprietary or third-party model portfolios. The use of any model portfolio is not required, and an IAR may elect to manage a client’s assets outside of a model portfolio based on the client’s goals, objectives, time horizon, risk tolerance, asset size, and other relevant considerations. Products or strategies that include performance-based compensation, whether offered directly by INDSQUARE or through affiliated investment vehicles, are not available through INDSQUARE’s wrap fee program, model portfolios, or standard discretionary advisory programs. Participation in such arrangements is limited to clients who separately elect to participate and agree to the applicable terms. Differences in fee arrangements, compensation structures, and revenue generation may also create conflicts of interest. Clients participating in performance-based arrangements 30  or affiliated investment products may generate greater compensation for INDSQUARE, its affiliates, or certain executive management personnel than other clients. These differences may create incentives to allocate additional time, attention, or resources to certain accounts or investment opportunities. INDSQUARE seeks to manage these conflicts in a manner consistent with its fiduciary obligations by maintaining written policies and procedures designed to promote fair and equitable treatment of clients. These controls include, among other things: • Review of recommendations involving performance-based or affiliated investment products; • Verification of client eligibility and documentation of informed consent; • Oversight of allocation practices, including use of proprietary or third-party model portfolios; and • Coordination with affiliated advisers to monitor and address potential side-by-side management conflicts. INDSQUARE endeavors to make investment recommendations in good faith and in a manner it believes to be fair, consistent with client objectives, and in compliance with applicable regulatory requirements. Item 7: Types of Clients INDSQUARE generally provides advisory services to the following types of clients: Individuals • • High-Net-Worth Individuals • Retirement Plans • Corporations • Charitable Organizations • State or Municipal Government Entities We generally do not require a minimum to establish or maintain a client’s account; however, minimum account size or investment requirements may apply to certain account types or investments, and individual Investment Adviser Representatives may establish their own minimums based on the nature of the services provided. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis 31  INDSQUARE’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. INDSQUARE uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data, primarily price and volume. Investment Strategies INDSQUARE uses long term trading, short term trading, short sales, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing involves risks including possible loss of principal. No investment strategy or risk management technique can guarantee return or eliminate risk in all market environments. B. Material Risks Involved in Analysis and Investment Strategies Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would assume that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors 32  begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies Certain strategies that we may use, such as short sales, margin transactions, and options trading, generally hold greater risk of capital loss but you should be aware that there is a material risk of loss using any investment strategy. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold, thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as 33  the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Selection of Other Advisers: Although INDSQUARE seeks to select only money managers who will invest our clients' assets with the highest level of integrity, our selection process cannot ensure that money managers will perform as desired, and we have no control over the day-to-day operations of any selected money managers. INDSQUARE would not necessarily be aware of certain activities at the underlying money manager level, including a money manager's engaging in unreported risks, investment “style drift”, or even regulatory breaches or fraud. Short sales entail the possibility of infinite loss if the applicable security’s price increases. Short term trading risks include those related to liquidity, economic stability, and inflation, in addition to the long-term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing involves risks including possible loss of principal. No investment strategy or risk management technique can guarantee return or eliminate risk in all market environments. C. Material Risks Involved in Specific Securities in prior Investments, other than Treasury Inflation Protected/Inflation Linked Bonds, are not guaranteed or insured by the FDIC or any other government agency. This list is not all inclusive; therefore, you are encouraged to review all risks associated with any particular investment you are considering to purchase. Although, investing Cryptocurrencies are not currently defined as a security, since Cryptocurrency-related products are a security based on the structure of the investment company product, we are including risks associated with underlying Cryptocurrencies. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. Equity investing generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions, and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer- term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. 34  The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting, which we believe to be extremely unlikely; however, these investments do carry a small potential risk of losing share price value. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing, which is described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and also increasing complexity, conflicts of interest, and the possibility of inadequate regulatory compliance. Precious Metal ETFs specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are products for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment in the future. They are contracts issued by an insurance company and are designed to meet retirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments and are not suitable for meeting short- term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks because assets are invested in the markets. Hedge funds often engage in leveraging and other speculative practices that may increase your risk of loss. They can be highly illiquid, are not required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Hedge funds are not subject to the same regulatory requirements as other investments such as mutual funds and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies which may not be transparent to you. Private equity funds carry certain risks. Capital calls will generally be made on short notice and the failure to meet these calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private placements carry a substantial risk as they are subject to less regulation than 35  publicly offered securities, and the market to resell these assets may be illiquid. Liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development, with the goal of generating a return through an eventual realization event. The risk is high because of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints, and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price and contain the risk that they will expire without providing any return to you. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk, and therefore, the risk you bear is limitless. Options transactions also involve risks including but not limited to economic risk, market risk, sector risk, political/regulatory risk, inflation (purchasing power) risk, and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting, and the lesser degree of accurate public information available. Cryptocurrencies (hereinafter, “Digital Assets”) involves risks, including extreme volatility, that may continue indefinitely and may create a future material adverse effect on the value of the asset. Digital assets were introduced within the past two decades, and the medium-to-long term value of the assets is subject to several factors relating to the capabilities and development of blockchain technologies and to the fundamental investment characteristics of Digital Assets. The volatility of Digital Assets and cryptocurrencies are subject to a few risk factors including, but not limited to, the following: • the economic conditions in the Digital Asset industry and market (such as an increase in the global supply of such Digital Asset(s)); and or • manipulative activity on Digital Asset exchanges; and or forks in the applicable Digital Asset network; and or • • scaling challenges in the effort to increase the volume and speed of transactions; and or • changes in laws or regulations, including those concerning taxes made by governmental authorities or regulatory bodies; and or • litigation or regulatory investigations concerning the Digital Assets classification under the federal securities laws and the costs and effect of any litigation or regulatory investigations; and or • general economic, market and business conditions; and other global or regional political, economic, or financial conditions, events and situations, such as pandemic outbreak, hackers or other malicious actors, destruction of Digital Assets, reliance 36  on Digital Asset service providers, and general governmental oversight of Digital Assets. Digital Asset investors are necessarily subject to the risk brought by the fact that Digital Assets represent a new and rapidly evolving industry. The unregulated nature and lack of transparency surrounding the operations of Digital Asset exchanges create an opportunity for investors to experience fraud, security failures, or operational problems, which may adversely affect the value of the Digital Assets. Investors are also subject to the risk of changes in the governance of Digital Assets and Digital Asset exchanges. Digital Asset values can fluctuate substantially, which may result in a total loss of the value of the digital assets. The supply of digital assets available to us may depend on third party providers and in such instances, is outside of our control. We do not own or control any of the protocols that are used in connection with Digital Assets and their related networks. Accordingly, we disclaim all liability relating to such protocols and any change in the value of any digital assets. We make no guarantees regarding the security, functionality, or availability of such protocols or Digital Asset networks. You accept all risks associated with Digital Asset transactions, including, but not limited to, those in connection with the failure of hardware, software, and internet connections. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. D. Pandemic Outbreak Risk The recent global outbreak of the 2019 novel coronavirus (“COVID-19”), together with resulting voluntary U.S. federal/state and non-U.S. governmental actions including, without limitation, mandatory business closures, public gathering limitations, and restrictions on travel and quarantines, has meaningfully disrupted the global economy and markets. Although the long-term economic fallout of COVID-19 is difficult to predict, it has and is expected to continue to have ongoing material adverse effects across many aspects of the regional, national, and global economies. In particular, the COVID-19 outbreak has already, and will continue to, affect investments and the industries in which they operate. Furthermore, our ability to operate effectively, including the ability of our personnel or our service providers and other contractors to function, communicate, and travel to the extent necessary to carry out our business has been, and will continue to be, impaired. The spread of COVID-19 among our personnel and our service providers would also significantly affect our ability to properly oversee the affairs of our clients’ accounts. Although INDSQUARE has a Business Continuity Plan in place, it is impossible to predict or foresee every potential situation which could affect client accounts. E. Cybersecurity Risk In addition to the Material Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at 37  INDSQUARE, or one of our third-party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or other misuse of confidential information, or generally compromise our ability to conduct our business. A cybersecurity breach may also result in a third party obtaining unauthorized access to confidential client information including social security numbers, home addresses, account numbers, account balances, and account holdings. INDSQUARE has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because INDSQUARE does not directly control the cybersecurity systems of issues, trading counterparties, or third-party service providers. There is also a risk that cybersecurity breaches may not be detected. Item 9: Disciplinary Information As a Registered Investment Adviser, INDSQUARE is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of our advisory business or the integrity of our management. INDSQUARE and our management personnel have no reportable disciplinary events to disclose. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Certain representatives of INDSQUARE are registered representatives of LPL Financial and when acting in this capacity, these representatives accept compensation for the sale of securities. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither INDSQUARE nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor, or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests In addition to providing investment advisory services through Independence Square Holdings, LLC (“INDSQUARE”), certain representatives may also sell or recommend securities and insurance products when acting in their separate capacities as registered representatives of LPL Financial LLC and/or as licensed insurance agents. Investments in securities or insurance products offered through these third-party arrangements are not 38  included when calculating the advisory fees charged by INDSQUARE. However, representatives may receive commissions, sales charges, trails, or other compensation in connection with the sale of such products, and the amount of such compensation may vary depending on the product or arrangement. When acting as a registered representative or insurance agent, a representative may have a financial incentive to recommend products for which they receive greater compensation than for other products. These incentives create conflicts of interest. INDSQUARE addresses these conflicts through disclosure, and policies and procedures designed to promote recommendations that are consistent with clients’ objectives and applicable fiduciary obligations. Clients are not required to purchase any securities or insurance products through an INDSQUARE representative and may obtain such products through other providers of their choosing. Certain representatives of INDSQUARE may also be associated with LPL Financial’s investment advisory business and, in that capacity, may provide discretionary investment management services to ERISA-covered plans as an “investment manager” within the meaning of ERISA Section 3(38). When acting in this capacity, such representatives are supervised by LPL Financial and are required to comply with LPL Financial’s policies and procedures and applicable ERISA requirements. Third-Party Providers and Ancillary Services In the course of providing investment advisory, financial planning, and consulting services, Independence Square Holdings, LLC (“INDSQUARE”) and its Investment Adviser Representatives (“IARs”) may recommend or facilitate access to certain unaffiliated third- party providers, platforms, or services that an IAR believes may complement a client’s overall financial strategy (“Ancillary Services”). Ancillary Services are optional, may not be appropriate for all clients, and may not be available through all IARs. Ancillary Services may include, but are not limited to: • Estate planning software and document preparation tools made available through adviser-licensed platforms (e.g., Wealth.com) (e.g., Caribou Health • Healthcare cost analysis and planning platforms Technologies) • Cash management programs (e.g., StoneCastle Network, LLC) Insurance brokerage services (e.g., Johnson, Kendall & Johnson, Inc.) • • Mortgage origination services (e.g., Rocket Pro TPO) • Digital asset platforms and custody solutions (e.g., HeightZero, LLC and BitGo Trust Company) • Self-directed brokerage account (“SDBA”) advisory arrangements Except as described below with respect to adviser-licensed planning tools, INDSQUARE does not control the operations, fees, or service offerings of third-party providers and does not supervise or monitor such providers. Clients who elect to utilize Ancillary Services generally enter into separate agreements directly with the applicable third-party 39  provider and are responsible for reviewing and understanding all terms, risks, and costs associated with those services. With respect to adviser-licensed estate planning software and document preparation tools (such as Wealth.com), clients do not enter into a contractual relationship with the software provider and do not pay fees directly to the provider. Access to these tools is made available through an IAR as part of INDSQUARE’s financial planning and consulting services. IARs who elect to offer access to such tools pay licensing fees directly to the software provider. An IAR may, in their discretion, charge a fixed, hourly, or asset-based fee for financial planning or consulting services that include access to these tools pursuant to the client’s Financial Planning and Consulting Agreement with INDSQUARE. Any such fee represents compensation for advisory services and is not a pass-through or third-party platform fee. Fees charged by third-party providers for Ancillary Services (other than adviser-licensed planning tools) are separate from, and in addition to, advisory fees charged by INDSQUARE and are paid directly to the applicable provider or deducted pursuant to the provider’s own billing practices. In certain cases, INDSQUARE or its IARs may receive referral fees, commissions, licensing cost offsets, revenue sharing, or other compensation (including non-cash compensation) in connection with a client’s use of Ancillary Services. These arrangements create conflicts of interest because INDSQUARE or its IARs have a financial incentive to recommend such services. Clients are under no obligation to utilize any Ancillary Service or third-party provider recommended by INDSQUARE or its IARs and may select alternative providers of their choosing. Digital Assets and Cryptocurrency-Related Services Independence Square Holdings, LLC (“INDSQUARE”) may recommend exposure to digital assets or cryptocurrency-related products for certain clients where appropriate. Digital assets are speculative, involve substantial risk, and may experience significant volatility or loss of principal. Digital asset custody and trading services are provided by unaffiliated third-party custodians and platforms, including BitGo Trust Company and Equity Trust Company, pursuant to separate agreements between clients and the applicable provider. INDSQUARE does not take custody of client digital assets. Clients who utilize digital asset platforms may incur additional platform, custody, transaction, and technology fees that are separate from INDSQUARE’s advisory fees. INDSQUARE or its Investment Adviser Representatives (“IARs”) may have a financial incentive to recommend certain platforms or arrangements where advisory fees may be charged on eligible digital assets or where platform-related fees are passed through to clients. Clients are under no obligation to utilize any particular digital asset platform and may select alternative providers. Retirement Plans, SDBA Accounts, and ERISA Considerations INDSQUARE provides investment advisory and consulting services to employer- sponsored retirement plans, plan sponsors, and plan participants. These services may include plan-level investment consulting and participant-level investment advisory services, as described elsewhere in this Brochure. When providing non-discretionary investment advice to plan participants, INDSQUARE acts as a fiduciary within the meaning 40  of Section 3(21) of the Employee Retirement Income Security Act of 1974 (“ERISA”), limited to the scope of the advice provided. Except where expressly agreed to in writing, INDSQUARE does not serve as a plan administrator, trustee, or ERISA Section 3(38) investment manager. Investment recommendations provided to plan participants are generally limited to the investment options made available under the applicable retirement plan or, where permitted, the plan’s self-directed brokerage option (“SDBA”). SDBA advisory arrangements, where offered, may involve referrals to unaffiliated third- party investment advisers or platforms. In such cases, INDSQUARE or its IARs may receive referral compensation in connection with a participant’s engagement of a third-party adviser or service provider. These arrangements create conflicts of interest because INDSQUARE or its IARs benefit financially when a participant elects to engage a referred adviser. INDSQUARE seeks to mitigate these conflicts through disclosure and by requiring that any referral be consistent with the participant’s investment objectives. Plan participants are not required to utilize any third-party adviser and may manage their SDBA independently or engage an adviser of their choosing, subject to the terms of the applicable plan. Affiliated Entities and Private Fund Relationships INDSQUARE is a wholly owned subsidiary of ISQ Holdings Ltd. INDSQUARE is affiliated with ISQ Capital LLC, also a wholly owned subsidiary of ISQ Holdings Ltd. Certain IARs of INDSQUARE may also be associated with ISQ Capital LLC, and certain representatives associated with INDSQUARE may be dually registered as registered representatives of LPL Financial LLC. When acting in separate capacities, such individuals operate under the supervision, policies, procedures, and compensation structures of the respective firm. INDSQUARE is not the investment manager to any private investment funds; however, INDSQUARE is affiliated with entities that sponsor and manage privately offered investment funds for which ISQ Capital LLC serves as investment manager. In addition, certain executive management personnel of INDSQUARE may have ownership interests in, and participate in the management or oversight of, such private investment funds through their roles with the affiliated adviser. These affiliations and ownership interests create conflicts of interest, including incentives related to fund management, compensation structures, and the allocation of investment opportunities. Such conflicts are disclosed in this Brochure and in the applicable private fund offering documents and are addressed through disclosure and the adoption and enforcement of written policies and procedures. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections INDSQUARE may, in its discretion, select and recommend unaffiliated third-party investment advisers or managers to manage all or a portion of a client’s assets. When a third-party adviser is engaged, clients generally pay INDSQUARE its advisory fee in addition to any fees charged by the third-party adviser. The applicable services and fee arrangements are disclosed in the client’s advisory agreement and in the third-party 41  adviser’s governing or disclosure documents. INDSQUARE conducts due diligence on third-party advisers prior to recommendation, which may include confirming that such advisers are appropriately registered, licensed, or notice-filed in the jurisdictions where services are provided, and reviewing information regarding the adviser’s investment approach, experience, and regulatory status. In certain arrangements, INDSQUARE or its Investment Adviser Representatives (“IARs”) may receive referral fees or other compensation from third-party advisers in connection with client referrals. Such compensation may be paid as a portion of the third-party adviser’s fee and generally does not reduce the fees paid by the client to the third-party adviser unless otherwise disclosed. Referral arrangements, where applicable, are documented in written agreements between INDSQUARE and the third-party adviser and are structured to comply with applicable regulatory requirements. The receipt of referral compensation creates a conflict of interest because INDSQUARE and its IARs have a financial incentive to recommend third-party advisers that provide such compensation. INDSQUARE seeks to address this conflict through disclosure and by evaluating third-party advisers based on factors such as investment strategy, experience, risk management practices, and overall suitability for the client’s objectives. Clients are under no obligation to engage any recommended third-party adviser and may select an adviser of their choosing. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics We take pride in our commitment to serve our clients’ needs with integrity and have developed a Code of Ethics to address issues such as: • Compliance with Laws and Regulations • Conflicts of Interest • Prohibited Purchases and Sales • Political and Charitable Contributions • Gifts and Entertainment • Confidentiality • Compliance Officer Duties • Personal Transaction Reporting • Reporting Violations Each person associated with INDSQUARE has been given a copy of the Code of Ethics and has submitted an acknowledgement attesting to their understanding of the Code and acceptance of its terms. A copy of our Code of Ethics is available to all current and/or prospective clients upon request. 42  B. Recommendations Involving Material Financial Interests INDSQUARE does not recommend that clients buy or sell any security in which we or any person related to us have a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of INDSQUARE may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives to buy or sell the same securities before or after recommending the same securities to clients, resulting in representatives profiting from the recommendations they provide to clients. Such transactions may create a conflict of interest. INDSQUARE documents transactions that could be construed as conflicts of interest, and it is our policy to never engage in trading that operates to a client’s disadvantage when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker-Dealers Custodians/broker-dealers will be recommended based on our duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. You may not necessarily pay the lowest commission or commission equivalent, and we may also consider the market expertise and research access provided by the broker/dealer custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in our research efforts. INDSQUARE will never charge a premium or commission on transactions which are beyond the actual cost imposed by the broker- dealer/custodian. INDSQUARE currently requires our clients to use LPL Financial, Charles Schwab & Co., Inc., Fifth-third Securities Inc., Equity Trust Company, StoneX Financial, or any broker- dealer utilized by AssetMark, Absolute Capital Management LLC, or The Pacific Financial Group Inc. B. Research and Support Provided by Financial Institutions INDSQUARE receives research, computer software, and related systems support at a discount or without cost from some of our custodial firms. These items allow us to better monitor client accounts maintained at these custodians. INDSQUARE receives the research, software, and related support at a discount or without cost because we render investment management services to clients that maintain assets at those broker-dealer firms. The research, software, and related systems support may benefit INDSQUARE but not our clients directly. These benefits are not directly tied to client account transactions and therefore they are not considered “soft dollars”. 43  In addition to the above items, our list of custodians may provide other products and services to assist us in managing and administering our clients’ accounts. These include software and other technology that: provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of INDSQUARE’s fees from our clients’ accounts (when applicable), and assist with back-office training/support functions, recordkeeping, and client reporting. Many of these services may be used to service all or a substantial number of our accounts. These firms also make available to INDSQUARE other services intended to help us manage and further develop our business enterprise. These services may include professional compliance, legal and business consulting, publications, and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance, and marketing. In addition, one or more custodians may arrange for and/or pay vendors for these types of services rendered to INDSQUARE by independent third parties. They may discount or waive fees they would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to us. INDSQUARE is independently owned and operated and is not affiliated with any custodian or Broker/Dealer, and in fulfilling our duties to our clients, we always endeavor to put the interests of our clients first. You should be aware, however, that INDSQUARE’s receipt of economic benefits from a financial institution creates a conflict of interest since these benefits provide an incentive for us to choose one institution over another that does not furnish similar research, software, support, or services. C. Brokerage for Client Referrals INDSQUARE receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. D. Clients Directing Which Broker/Dealer/Custodian to Use INDSQUARE may require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. E. Aggregating (Block) Trading for Multiple Client Accounts If we buy or sell the same securities on behalf of more than one client, then we may (but are under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, INDSQUARE would place an aggregate order with the broker on behalf of all such clients to ensure fairness for all clients and these trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. INDSQUARE would determine the appropriate number of shares and select the appropriate brokers consistent with our duty to seek best execution. 44  Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Representatives of the firm provide ongoing oversight of investments for accounts managed on a discretionary basis. Client accounts are reviewed periodically to assess whether portfolio holdings remain consistent with the applicable investment strategy and the client’s stated investment objectives. The frequency and scope of such reviews may vary based on factors such as the type of account, investment strategy, market conditions, and client circumstances. Accounts receiving ongoing advisory services are subject to supervisory review in accordance with the firm’s compliance policies and procedures. Such reviews are conducted by appropriate supervisory or compliance personnel or their designees. Financial planning and consulting engagements are generally reviewed in connection with the preparation and delivery of the applicable plan or report. Financial planning services are typically provided on a one-time basis unless otherwise agreed in writing. Following delivery of a financial plan, the firm does not provide ongoing monitoring or updates unless the client separately engages the firm for additional planning services or ongoing advisory services, which may be subject to additional fees. Clients may request additional planning services, updates, or reports at a later date pursuant to a new or amended agreement and applicable fee arrangement. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in your financial situation (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients You will receive statements (at minimum quarterly with the exception of some insurance and annuity products) and confirmation of transactions from the custodian and not from INDSQUARE. Financial Planning and Consulting clients will not receive regular reports but may receive written reports from our representatives at their financial planning review sessions. These reports may include descriptions of holdings, total assets, current values, management fees, the method of fee calculation, or other details or analyses agreed to between you and our representative. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients 45  INDSQUARE may receive noncash compensation from third party advisers to which we direct clients or from firms that manage investment products that we select for our clients. In addition, some custodians or third-party Broker/Dealers may make available to INDSQUARE some products and services that benefit us but may not benefit our clients’ accounts. These benefits may include national, regional or firm-specific educational events organized and/or sponsored by a custodian or Broker/Dealer Other potential benefits may include occasional business entertainment of our personnel including meals, invitations to sporting events, golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Our custodians may also provide INDSQUARE with access to research, trading, and custody services which are typically not available to retail investors. B. Compensation to Non–Advisory Personnel for Client Referrals Independence Square Advisor’s may enter into written referral or solicitation arrangements with unaffiliated third parties (“promoters”) who introduce prospective clients to the Adviser. Any such arrangements are structured to comply with the Investment Advisers Act of 1940, including Rule 206(4)-1 thereunder, as well as applicable state securities laws. Under these arrangements, promoters may receive compensation from INDSQUARE for successful client referrals. Compensation may be structured as a retainer, a fixed fee per referred client, a percentage of advisory fees received, a percentage of capital introduced, or another mutually agreed-upon arrangement, as set forth in a written agreement between INDSQUARE and the promoter. Such agreements generally may be terminated by either party in accordance with their terms. INDSQUARE provides required disclosures regarding promoter arrangements to affected clients at or prior to the time of engagement, including disclosure of the nature of the referral relationship and the compensation paid to the promoter. Clients are not charged additional fees as a result of these arrangements, and the cost of any promoter compensation is borne entirely by your IAR. Item 15: Custody All client account assets are held by a qualified custodian, except in the case of Digital Asset custodians. Neither INDSQUARE nor our associated persons have custody of client assets. INDSQUARE does not hold or take custody of client personal securities or funds of any kind. We utilize independent unaffiliated third-party custodians to hold client assets and provide statements for each client. It is the custodian’s charge to safeguard and prevent unauthorized access from anyone. Please note that custodians may charge fees for their services. INDSQUARE is independently owned and operated and is not affiliated with any third- party custodians we use. The third-party custodians used by INDSQUARE do not charge 46  advisory clients separately for custody services but are compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through them or in their accounts. INDSQUARE is not responsible for the actions of a client’s custodian, and you should carefully review the account statements you receive from them. In some cases, INDSQUARE may provide an account statement or summary. We urge you to compare the account statement you receive from your qualified custodian with the documents provided by us. As part of account opening and ongoing servicing, clients may be required to provide identifying information and documentation to satisfy identity verification, fraud prevention, or similar requirements imposed by custodians, financial institutions, or third- party service providers. Failure to provide required information may result in delays or limitations in account opening or access to certain services. These requirements are generally imposed by third parties and are separate from the advisory services provided by the Adviser. Item 16: Investment Discretion For discretionary accounts, clients enter into a written investment advisory agreement with Independence Square Holdings, LLC that grants INSQUARE ongoing discretionary authority to manage the account in accordance with the client’s stated investment objectives, guidelines, and any written restrictions. Clients are also required to execute all custodial documents necessary to authorize INDSQUARE to effect transactions in the account. Subject to the terms of the advisory agreement and applicable investment guidelines, INDSQUARE is authorized, in its discretion and without obtaining prior client approval for each transaction, to: • purchase, sell, exchange, or otherwise trade securities and other investment instruments; • determine the type, quantity, and timing of securities or investments to be purchased or sold; and • place orders and direct transactions through the account’s designated custodian. INDSQUARE’s discretionary authority may be limited by client-imposed restrictions, investment guidelines, or other instructions provided by the client in writing and accepted by INDSQUARE. Clients may modify or revoke such discretionary authority at any time by providing written notice, subject to the terms of the advisory agreement and applicable custodial requirements. Item 17: Voting Client Securities (Proxy Voting) INDSQUARE will not ask for, nor accept, voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian and you retain sole responsibility for voting. You should direct all proxy questions to the issuer of the 47  security. Item 18: Financial Information A. Balance Sheet INDSQUARE neither requires, nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients In response to the COVID-19 pandemic and related market conditions, Independence Square Holdings, LLC (“INDSQUARE”) participated in the Paycheck Protection Program (“PPP”) established under the CARES Act to support business continuity and employee payroll. The PPP loan was used primarily to continue payroll and operating expenses during that period and was subsequently forgiven in full in accordance with program requirements. INDSQUARE does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. The firm continues to operate as a going concern and maintains sufficient financial resources to provide advisory services to its clients. C. Bankruptcy Petitions in Previous Ten Years INDSQUARE has not been the subject of a bankruptcy petition in the last ten years. 48