INSIGHT FOLIOS INC

Insight Folios Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Insight Folios (INS). If you have any questions about the contents of this brochure, please contact us at 704-529-9500 or by email at: Paul@Insightfolios.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Insight Folios is also available on the SEC’s website at www.adviserinfo.sec.gov. Insight Folios’ CRD number is: 174411. 10800 Sikes Pl ste 110 Charlotte, NC 28277704-529-9500 Paul@InsightFolios.com Registration does not imply a certain level of skill or training. Version Date: 03/31/2025 i  Item 2: Material Changes The material changes in this brochure since Insight Folios' last annual updating amendment dated 2/12/2024 are described below. Material changes relate to Insight Folios policies, practices or conflicts of interest. • Bryan R. Dustman is now serving as Chief Compliance Officer of Insight Folios, effective January 1, 2025. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ........................................................................................................................................... ii Item 3: Table of Contents ...........................................................................................................................................iii Item 4: Advisory Business........................................................................................................................................... 5 A. Description of the Advisory Firm ....................................................................................................................... 5 B. Types of Advisory Services ................................................................................................................................. 5 C. Client Tailored Services and Client Imposed Restrictions ................................................................................ 12 D. Wrap Fee Programs ......................................................................................................................................... 13 E. Assets Under Management .............................................................................................................................. 13 Item 5: Fees and Compensation............................................................................................................................... 13 A. Fee Schedule .................................................................................................................................................... 13 B. Payment of Fees ............................................................................................................................................... 15 C. Client Responsibility for Third Party Fees ........................................................................................................ 16 D. Prepayment of Fees ......................................................................................................................................... 16 E. Outside Compensation for the Sale of Investment Products to Clients .......................................................... 16 Item 6: Performance-Based Fees and Side-By-Side Management .......................................................................... 20 Item 7: Types of Clients ............................................................................................................................................ 20 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss .................................................................... 21 A. Methods of Analysis and Investment Strategies ....................................................................................... 21 B. Material Risks Involved .............................................................................................................................. 21 C. Risks of Specific Securities Utilized ............................................................................................................ 22 Item 9: Disciplinary Information .............................................................................................................................. 37 A. Criminal or Civil Actions ............................................................................................................................. 37 B. Administrative Proceedings ....................................................................................................................... 37 C. Self-regulatory Organization (SRO) Proceedings ....................................................................................... 37 Item 10: Other Financial Industry Activities and Affiliations ................................................................................... 37 A. Registration as a Broker/Dealer or Broker/Dealer Representative ........................................................... 37 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading B. Advisor .................................................................................................................................................................. 37 C. Registration Relationships Material to this Advisory Business and Conflicts of Interests ........................ 38 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections.. 39 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................. 39 iii  A. Code of Ethics ............................................................................................................................................ 39 B. Recommendations Involving Material Financial Interests ........................................................................ 39 C. Investing Personal Money in the Same Securities as Clients .................................................................... 39 D. Trading Securities At/Around the Same Time as Clients’ Securities ......................................................... 40 Item 12: Brokerage Practices ................................................................................................................................... 40 A. Factors Used to Select Custodians and/or Broker/Dealers ....................................................................... 40 1. Research and Other Soft-Dollar Benefits ............................................................................................... 41 2. Brokerage for Client Referrals ................................................................................................................ 43 3. Clients Directing Which Broker/Dealer/Custodian to Use ..................................................................... 43 B. Aggregating (Block) Trading for Multiple Client Accounts ........................................................................ 43 Item 13: Reviews of Accounts .................................................................................................................................. 47 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews .......................................... 47 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ........................................................ 47 C. Content and Frequency of Regular Reports Provided to Clients ............................................................... 48 Item 14: Client Referrals and Other Compensation ................................................................................................. 48 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or A. Other Prizes) ......................................................................................................................................................... 48 B. Compensation to Non – Advisory Personnel for Client Referrals ............................................................. 48 Item 15: Custody ...................................................................................................................................................... 49 Item 16: Investment Discretion ................................................................................................................................ 49 Item 17: Voting Client Securities (Proxy Voting) ...................................................................................................... 50 Item 18: Financial Information ................................................................................................................................. 50 A. Balance Sheet ............................................................................................................................................ 50 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients 50 C. Bankruptcy Petitions in Previous Ten Years .............................................................................................. 50 iv  Item 4: Advisory Business A. Description of the Advisory Firm Insight Folios, Inc. dba Insight Folios (hereinafter “INS”) is a Corporation organized in the State of Michigan. The firm was formed in December 2014, and the principal owner is Paul L. Durso. B. Types of Advisory Services Portfolio Management Services INS offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. INS creates an Investment Policy Statement and/or Simplicitree Plan for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy Asset allocation Risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring INS evaluates the current investments of each client with respect to their risk tolerance levels, income needs, and time horizon. INS typically operates on a discretionary basis and will request discretionary authority from clients to select securities and execute transactions without prior client approval. Non- discretionary arrangements may be available upon request and mutual agreement. • Discretionary Authority Discretionary authority is when you give Advisor the power to make decisions about your investments without asking you first. Here's what it means: o What It Is: Your advisor can buy or sell stocks and manage your investments as they see fit, based on what you both agreed upon in your investment plan. o How It Works: You sign a special agreement giving your advisor this power. This agreement says what the advisor can do and makes them your representative for managing your investments. Discretionary authority allows Advisor to act fast to take advantage of market opportunities or potentially avoid losses without waiting for your approval. Clients can rely on Advisor knowledge to make smart investment choices where you don’t need to be involved in every decision, saving you time and effort. In short, discretionary authority means you let your advisor handle the day-to-day management of your investments, so you can focus on other things in life. It works best when there is trust and clear communication about your financial goals. • Non-Discretionary Authority Page 5 of 50  Non-discretionary authority refers to an arrangement where the Advisor provides recommendations and advice to the client, but the client retains full control over all investment decisions. In a non-discretionary arrangement, the client makes the final decision on all investment actions. While the advisor provides expert recommendations, the client must approve each transaction before it is executed. The advisor's role is to analyze the client's financial situation, risk tolerance, and investment goals to provide tailored advice. Advisor suggest investment strategies, potential securities to buy or sell, and adjustments to the portfolio, but they do not execute any trades without the client's explicit consent. In some cases, the need for client approval can delay transactions, potentially missing out on timely market opportunities. Return and income needs are documented in the Investment Policy Statement and/or Simplicitree1 Plan, which is given to each client. INS makes investment decisions in accordance with the fiduciary duties owed to its accounts and without consideration of INS’s economic, investment or other financial interests. To meet its fiduciary obligations, INS attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, INS’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is INS’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Annual Planning Client circumstances are subject to change at any time with any frequency so advice cannot be viewed from the perspective of a static financial plan. The flexibility of the Simplicitree software greatly assists in guiding clients through “what if” scenarios as clients consider their future. INS’ comprehensive view of planning with clients includes: • Budgeting, personal liability, estate information and goals • Tax minimization and income strategies • Special planning requirements like travel expenses, long term care provision, the impact of rental property, etc. Investment analysis with respect to income generation potential, liquidity, and risk Insurance sufficiency – Long term care, life, health, etc. • • • Effective Social Security benefit decisions • Team of advisers approach – it is important for a client’s financial adviser, tax preparer and estate planning attorney to all understand and support the comprehensive plan for the client Sub-Advisory Services INS will act in the capacity of sub-adviser to other registered investment adviser firms. Financial Planning 1 Simplicitree is a planning tool under common control and ownership as Insight Folios. Page 6 of 50  INS provides financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service develop and receive a personalized Simplicitree Report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas: PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals. TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current, and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio. INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income. ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid, and elder law. When client requires services and expertise that is outside the realm in which we practice, we help the client engage professional specialists in these areas and work as a team for the client's benefit. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We, or the outside professionals involved, carefully review documents supplied by the client, and where appropriate, we then enter their information into the Simplicitree Software and deliver a report to the client. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. Page 7 of 50  We also discuss general non-securities topics that may include tax and budgetary planning, estate planning and business planning. INS does not provide tax or legal advice. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. ERISA Plan Advisory Service INS offers advisory services to ERISA Plans. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Investment Advisor Representatives assist Clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or non-discretionary advisory services. Investment Advisor Representatives perform one or more of the following services, as selected by the Client in the Client agreement: • Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan based upon consultation with client to ascertain Plan’s investment objectives and constraints. • Acting as a liaison between the Plan and service providers, product sponsors or vendors. • Ongoing monitoring of investment manager(s) or investments in relation to written guidelines provided by the Client to the Investment Advisor Representative. • Preparation of reports describing the performance of Plan investment manager(s) or investments, as well as comparing the performance to benchmarks. • Ongoing recommendations for consideration and selection by Client about specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan. • Training for the members of the Plan Committee with regard to their service on the Committee, including education and consulting with respect to fiduciary responsibilities. • Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, Representatives may provide participants with information about the Plan, which includes information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan. Page 8 of 50  • Assistance with investment education seminars and meetings for Plan participants. Such meetings may be on a group or individual basis, and includes information about the investment options under the Plan (e.g., investment objectives, risk/return characteristics, and historical performance), investment concepts (e.g., diversification, asset classes, and risk and return), and how to determine investment time horizons and assess risk tolerance. Such meetings do not include specific investment advice about investment options under the Plan as being appropriate for a particular participant. • Assistance at Client’s direction in making changes to investment options under the Plan. • Assistance with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support in connection with vendor analysis and service provider support. • Preparation of comparisons of Plan data (e.g., regarding fees and services and participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans. • Assistance in identifying the fees and other costs borne by the Plan for, as specified by Client, investment management, record keeping, participant education, participant communication and/or other services provided with respect to the Plan. If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the Plan, Investment Advisor Representatives do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan invest the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or obtain participant loans, Investment Advisor Representatives do not provide any individualized advice or recommendations to the participants regarding these decisions. If a Client elects to engage the firm and our Investment Advisor Representatives to perform ongoing investment monitoring and ongoing investment recommendation services in the Client agreement, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Therefore, the firm and our Investment Advisor Representative will be deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA in connection with those services. ERISA Fiduciary Advisor's services are governed by the Advisers Act of 1940, and they act as fiduciaries under this law. When a client hires an Investment Advisor Representative for continuous investment monitoring and recommendations for a Plan under ERISA, these services count as "investment advice," making the representative a fiduciary under ERISA. However, if the advisor performs other services outside ongoing investment monitoring and recommendations, those are not considered "investment advice" under ERISA, and the advisor is not a fiduciary for such services. The advisor might inform the Plan or its participants about additional services separate from Retirement Plan Consulting. When offering these separate services, the advisor is not a fiduciary under ERISA. Clients should evaluate these additional services independently without relying on the advisor's advice. Plan Participant Advisory Services (PPAS) Page 9 of 50  Investment advisor representatives can provide tailored asset allocation and investment recommendations for retirement plan assets based on the client's financial information and investment objectives. They may have the authority to execute trades directly or the client may choose to handle transactions themselves. Fees are determined by the representative based on factors like asset amount and service complexity, and clients should consider these when negotiating. Fees are paid by check to the Advisor. Clients can terminate the arrangement anytime and request a refund for unearned fees based on work completed before termination. The agreement ends upon the delivery of a recommendation, with no refunds after delivery unless the time spent is less than expected. Retirement Plan Rollovers An employee generally has four (4) options for their retirement plan when they leave an employer: 1. Leave the money in his/her former employer’s plan, if permitted 2. Rollover the assets to his/her new employer’s plan if one is available and permitted 3. Rollover to an Individual Retirement Account (IRA), or 4. Cash out the account value, which has significant tax considerations Advisor provides educational services pertaining to retirement plan assets that could potentially be rolled-over to an IRA managed by the firm. Education is based on a particular Client’s financial circumstances. Advisor has an incentive to recommend such a rollover based on the compensation received, which is mitigated by the fiduciary duty to act in a Client’s best interest and acting accordingly. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: • Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. • Employer retirement plans generally have a more limited investment menu than IRAs. • Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. • Your current plan may have lower fees than our fees. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because Investment Advisor Representatives have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should Page 10 of 50  consider the costs and benefits of each. An employee will typically be investing only in mutual funds, you should understand the cost structure of the share classes, available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. Clients should understand the various products and services they might take advantage of at an IRA provider and the potential costs of those products and services. • Our strategy may have higher risk than the option(s) provided to you in your plan. • Your current plan may also offer financial advice. • If you keep your assets titled in a 401k or retirement account, participants could potentially delay their required minimum distribution beyond age 70½. • A 401(k) may offer more liability protection than a rollover IRA; each state may vary. • Participants may be able to take out a loan on your 401k, but not from an IRA. • IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. • If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital gains tax rate. • Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. It is important to understand the differences between these types of accounts and to decide whether a rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative, or call our main number as listed on the cover page of this brochure. Selection of Other Advisers INS may direct clients to third party money managers. INS will be compensated via a fee share from the advisors to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other advisors for clients, INS will always ensure those other advisors are properly licensed or registered as an investment advisor. Services Limited to Specific Types of Investments INS generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold Page 11 of 50  and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, and private placements. INS may use other securities and investment vehicles as well to help diversify a portfolio when deemed appropriate based on the client's investment objectives and risk tolerance. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • • • • • • Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions INS offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement and/or Simplicitree Plan which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent INS from properly servicing the client account, or if the restrictions would require INS to deviate from its standard suite of services, INS reserves the right to end the relationship. Artificial Intelligence Artificial Intelligence (AI) is the simulation of human intelligence in machines designed to think and learn like humans. AI encompasses a range of technologies that enable systems to perform tasks such as recognizing speech, making decisions, and understanding complex ideas. AI enhances our services, improves operational efficiency, and delivers overall better outcomes. By integrating AI into our processes, we aim to stay at the forefront of technological innovation while maintaining a strong commitment to ethical practices and data privacy. Advisor has incorporating artificial intelligence (AI) into its practice to enhance service delivery, improve decision-making, and provide better outcomes for their clients. Page 12 of 50  D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. INS does not participate in any wrap fee programs. E. Assets Under Management INS has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 340,502,788 $ 880,483 March 2025 Item 5: Fees and Compensation A. Fee Schedule Asset-Based Fees for Portfolio Management Total Assets Under Management Annual Fee $0 - $ 999,999 2.59% $1,000,000 - $1,999,999 2.45% $2,000,000 - $4,999,999 2.30% $5,000,000 - and up Negotiated Asset-Based fees are negotiable at INS's discretion, and the final fee schedule is attached as an Exhibit of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of INS's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract upon thirty (30) days written notice. INS bills based on the last day of the previous quarter or previous month. Financial Planning Fees Fixed Fees INS’ Financial Planning fees are determined based on the nature and scope of services being provided and the complexity of each client’s circumstances. All fees are negotiated and agreed upon prior to entering into a contract with any client. For standard financial plans, INS typically charges a fixed fee Page 13 of 50  ranging from $2,500 to $5,000. For more limited scope engagements or ongoing consultations, INS charges an hourly fee of $250, with a typical engagement requiring between 8 and 20 hours. The decision between hourly and fixed fee arrangements will be based on the estimated time required, complexity of the planning needs, and client preference. The services provided in order to complete the financial plan are described more fully in Item 4, Advisory Services. If the plan is implemented through INS and the financial planning client chooses to engage INS for its Portfolio Management Services, INS reserves the discretion to reduce or waive the hourly fee and/or the financial plan fixed fee. Clients may terminate the agreement without penalty for a full refund of INS's fees within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. The agreement will automatically renew until otherwise canceled by either party. If the agreement is terminated, a refund will be made for services that have not been performed. ERISA Plan Advisory Service Fees The rate for ERISA Plan Advisory Services is between 0.25 - 0.75% of the plan assets for which INS is providing such consulting services. These fees are negotiable. Factors to determine the fee scale will be: the number of facilities and employees; travel time and/ or overnights required to service and/ or educate participants; • • • Number of Fiduciary Reviews per year (usual is 1 -2 per year) as well as travel time and/ or overnights required; • Number of Investment Committee meetings per year (usual is 1-4 per year) as well as travel time and/ or overnights required; • The frequency the plan sponsor wants the plan shopped for quotes and proposals or to benchmark the plan (usual is every 3 years); • The amount of assets in the plan as well as the annual flow of contributions and matches. Profit Share contributions are also important. Selection of Other Advisers: Fees INS may direct clients to third party money managers. INS will be compensated via a fee share from the advisors to which it directs those clients. This relationship will be disclosed in each contract between INS and each third-party adviser. The fees shared will not exceed any limit imposed by any regulatory agency. These third-party advisers are state or SEC registered investment advisers. Advisor helps clients choose a suitable third-party program by first understanding the client's financial situation and investment goals. Page 14 of 50  Advisor earns compensation for referring clients to these advisers and providing ongoing services. This compensation is disclosed separately and usually represents a portion of the third-party adviser's fee or a fixed fee. The disclosure clearly outlines how these fees affect the total charges to the client. Although different agreements with third-party advisers mean Advisor may earn varying compensation, it remains committed to acting in the client's best interests due to its fiduciary duty. Clients receive full disclosure about the services and fees from both the third-party adviser and Advisor, including the relevant Form ADV 2A documents. If a wrap fee program is recommended, clients also get the wrap fee brochure from the program sponsor. To engage with a third-party adviser, clients must enter into an advisory agreement and complete necessary documentation. While Advisor guides clients in selecting a third-party adviser, it does not manage accounts established with these third-party managers. B. Payment of Fees Payment of Asset-Based Fees for Portfolio Management Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization. These fees are withdrawn on either a quarterly basis in advance on the first business day of each quarter, or on a monthly basis in arrears on the first business day following the month end, as negotiated and disclosed in the Investment Advisory Contract. Fees are based on the assets under management on the last day of the prior period. For partial periods, fees will be prorated based on the number of days services were provided. For accounts opened mid-period, fees will be prorated from the date of inception to the end of the period. Payment of Financial Planning Fees Financial planning fees are paid via check or wire, or if the client has assets under management at INS, financial planning fees may be withdrawn directly from the client's accounts with the client's written authorization and may be withdrawn on a monthly or quarterly basis. Fixed financial planning fees are paid 100% in advance, but never more than six months in advance. Payment of ERISA Plan Advisory Services Fees ERISA Plan Advisory Services fees are paid on a monthly or quarterly basis, in arrears or in advance, as negotiated and presented in Exhibit I of the ERISA Plans Investment Advisory Agreement. The Client authorizes its platform provider to pay the fees due INS. Payment of Selection of Other Advisers Fees Clients will be billed per the Agreement entered into by and between the Client and the Third-Party. Page 15 of 50  C. Client Responsibility for Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by INS. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees INS collects certain fees in advance as specified in this agreement. Any refunds for fees paid in advance will be processed within fourteen (14) business days of termination and returned to the client via check or direct deposit back into the client’s account. The client may specify their preferred refund method in writing. 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. E. Outside Compensation for the Sale of Investment Products to Clients Charles Buddy Bowers Jr., Kenneth Lee Huffman, Bruce Romagnoli, Kevin Wray, Paul L. Durso, Ashok S Ramji, David Kyle Morgan, Sean Richard Sparkman, Ryan McNeill, Niki Waters Erb, Salvatore Bonetti, Larry Gene McCabe, Sheila Rene Madrigal, Zach Poitra and Charles Dingman in their outside business activities (see Item 10 below) are licensed to accept compensation for the sale of investment products to INS clients. • This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receive compensation, INS will: (1) document the conflict of interest in the client file, (2) provide written disclosure to the client detailing the specific nature of the conflict and compensation structure, and (3) obtain written acknowledgment from the client prior to proceeding with the transaction. and inform the client of the conflict of interest. • Clients always have the right to decide whether to purchase INS-recommended products and, if purchasing, have the right to purchase those products through other brokers or agents that are not affiliated with INS. • Commissions are not INS’s primary source of compensation for advisory services. Page 16 of 50  • Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Mutual Fund Share Class Disclosures Section 206 of the Investment Advisers Act of 1940 (“Advisers Act”) imposes a fiduciary duty to act in a client’s best interests and specifically prohibits investment advisers, directly or indirectly, from engaging in any transaction, practice, or course of business which operates as a fraud or deceit upon any client or prospective client. However, the fiduciary duty to which advisers are subject is not specifically defined in the Advisers Act or the Commission rules but reflects a Congressional recognition “of the delicate fiduciary nature of an investment advisory relationship” as well as a Congressional intent to eliminate, or at least expose, all conflicts of interest which might incline an investment adviser, consciously or unconsciously, to render advice which was not disinterested. The purpose of 12b-1 fees, as approved by the SEC, are to cover marketing expenses and shareholder services such as the support services. Mutual funds offer different share classes, each with varying fee structures and features, to accommodate different types of investors. Below is a breakdown of the most common mutual fund share classes. • Class A Shares: These shares typically charge a front-end sales load, which is a fee paid when the shares are purchased. This fee is a percentage of the total investment. o Generally have lower ongoing expenses compared to other share classes because the front-end load compensates the broker or advisor for their services. o Investors can receive discounts on the front-end load based on the size of the investment, known as breakpoint discounts. • Class B Shares: Class B shares often have a contingent deferred sales charge (CDSC), which is a fee paid when shares are sold, typically decreasing over time (usually over six to eight years). o These shares generally have higher ongoing expenses than Class A shares. o Usually convert to Class A shares after the CDSC period ends, resulting in lower ongoing fees. • Class C Shares: Class C shares typically charge a level load, which is an annual fee as long as the shares are held, in addition to higher ongoing expenses. o Unlike Class B shares, Class C shares do not convert to Class A shares, meaning the higher fees continue indefinitely. o Include 12b-1 fees to cover marketing and distribution expenses. o Often have a small back-end load if shares are sold within a short period (usually one year). • Class I Shares: also known as Institutional Shares, are a class of mutual fund shares designed primarily for institutional investors, such as pension funds, endowments, and large-scale investment managers. o Typically have lower expense ratios compared to other share classes, such as A, B, or C shares. This is because institutional investors usually invest larger amounts, allowing the fund to spread its costs over a larger asset base. Page 17 of 50  o Generally require a higher minimum investment, often starting at $500,000 or more, making them more suitable for institutional investors or high-net-worth individuals. • R Shares: Designed for retirement plans like 401(k) plans. o Offer various fee structures to meet the needs of different retirement plan sponsors. o Each share class is structured to meet the needs and preferences of different investors, balancing the cost of investing with the services provided. The choice between them should be based on the investor's financial situation, investment goals, and how long they plan to hold the investment. • NTF (No Transaction Fee) Mutual Funds: Mutual funds without a transaction fee or commission to the brokerage or platform through which they are purchased. o Not all funds are available as NTF funds, can be subject to minimum investment amounts, and availability can vary by broker/dealer o Some NTF mutual funds include 12b-1 fees as part of their expense structure. This helps the fund cover distribution and marketing costs, potentially allowing the fund to be offered without transaction fees. • Direct Purchase Mutual Funds: Often available directly from the mutual fund company. Direct purchase mutual funds can be a cost-effective option for knowledgeable investors who are comfortable managing their own investments and wish to avoid intermediary fees. However, it requires a proactive approach to research and decision-making. The choice of the most beneficial mutual fund share class involves considering ticket charges, 12b-1 fees and the asset management fee. Fees are considered in totality, not in isolation. Sometimes, investing in a share class with 12b-1 fees can be the more cost-effective option rather than simply avoiding 12b-1 fees. Advisor has a fiduciary duty to select the share class that best serves the client's interests, ensuring a comprehensive fee analysis to determine the optimal choice. For a wrap fee account, a different conflict of interest is introduced because the advisor has an incentive to not trade as frequently (reverse churning) to avoid the ticket charges which can compromise active management. This conflict is mitigated by the fiduciary duty to act in a client’s best interest while also considering the higher asset management fee charged for wrap fee accounts. Legacy Mutual Fund Holdings When a client moves their assets into a managed account, the portfolio advisor reviews the client's mutual fund holdings. If the mutual funds are not part of the Advisor's recommended list, they are generally sold unless selling would result in a taxable gain that outweighs the benefits of the preferred holdings or higher fee structure. If it is determined that converting the legacy positions to a different share class is in the clients best interest, Advisor will execute on such changes. Page 18 of 50  • Assessment: Advisor first conducts a thorough assessment of the client's current mutual fund holdings. This involves evaluating the fees, performance, and fit within the client's overall investment strategy and objectives. • Comparison: Advisor compares the current share class with alternative options available. This comparison includes analyzing expense ratios, 12b-1 fees, potential loads, and any other costs associated. • Eligibility & Requirements: Advisor ensures that the client meets any minimum investment amounts and other eligibility criteria required for the new share class. • Benefit Analysis: Advisor evaluates the potential benefits of conversion, such as lower fees, better alignment with investment goals, or improved tax efficiency. The goal is to determine whether the conversion will result in cost savings or other advantages for the client. After a conversion or decision to maintain a legacy position, Advisor continues to monitor the investment to ensure it remains aligned with the client’s goals. This ongoing review helps in making any necessary adjustments in the future. Compensation for Sales of Securities Advisor does not receive commission compensation for advisory services. Money Managers and Product Sponsors Investment advisor representatives are sometimes invited to attend training events or participate in due diligence visits sponsored by Money Managers or Product Sponsors. During these events, the sponsors often cover travel expenses like airfare, hotel accommodations, and meals. These training sessions are frequently held at luxury resorts, offering amenities such as golf, spas, and entertainment. While these opportunities are beneficial for gaining insights and understanding the products or services better, they also present a conflict of interest. The luxurious settings and covered expenses could unconsciously influence Advisor to favor these Money Managers or Product Sponsors, potentially affecting their objective evaluation of their quality. This could lead to recommendations based on the perks received rather than a client’s best interest. To mitigate this conflict of interest, Advisor operates with transparency and a fiduciary duty to act in a client’s best interest. Industry Professionals When it serves the best interests of the client, Advisor recommends the services of other professionals, such as attorneys or accountants, for non-investment-related needs. These introductions can be valuable in providing clients with comprehensive support and expertise beyond the Advisor's direct offerings, ensuring clients receive well-rounded assistance in various aspects of their financial and legal matters. Introducing clients to other professionals creates a conflict of interest because the referred professional might feel an implicit obligation to reciprocate by referring potential new clients back to the Advisor. This could influence recommendations, prioritizing professionals likely to reciprocate rather than solely considering the client's best interests. Page 19 of 50  Clients are under no obligation to use the services of a recommended professional. They are free to seek advice and services from other professionals of their choosing. Recommendation are merely a suggestion based on perceived quality and suitability; clients retain full discretion over whether to engage with the suggested professionals. If a client decides to engage with a referred professional and a dispute arises, the client’s recourse is solely against the engaged professional. Advisor does not assume responsibility for the actions or outcomes of services provided by third-party professionals. Clients should conduct their own due diligence and ensure they are comfortable with the terms and conditions proposed by the referred professional. Additional Compensation Advisor can receive economic benefits from sources other than the client for providing advisory services. These benefits can take various forms, including sales awards, gifts, meals, or entertainment such as tickets to concerts, shows, or sporting events. Here's a more detailed explanation: • Sales Awards: Recognitions or bonuses given for achieving certain targets or performance metrics, often provided by product sponsors or financial institutions. • Gifts: These can range from small tokens of appreciation to more significant items, potentially offered by business partners or vendors. • Meals & Entertainment: Occasional meals, invitations to events, or tickets to entertainment activities provided by third-party entities, such as product sponsors or other financial service providers. These economic benefits create a conflict of interest, as they can unconsciously influence decisions regarding the selection of products and/or services. For instance, an advisor might be more inclined to recommend products from a sponsor that offers more generous incentives. This influence can affect the objectivity of recommendations; however, Advisor has a fiduciary duty to act in a client’s best interest. Item 6: Performance-Based Fees and Side-By-Side Management INS does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients INS generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Other Investment Advisors Minimum Account Size There is no account minimum for any of INS’s services. Page 20 of 50  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis INS’s methods of analysis include fundamental analysis, technical analysis and cyclical analysis. • Fundamental Analysis: This method involves examining a company’s financial statements, market position, management quality, and economic conditions to estimate its intrinsic value. It helps investors identify stocks that are mispriced by the market. o Market prices may not reflect intrinsic value for extended periods. o Macro-economic factors can affect company performance unpredictably. • Technical Analysis: Focuses on historical price movements and trading volumes to forecast future price trends. Technical analysts use charts and other tools to identify patterns and indicators that suggest buying or selling opportunities. o Relies heavily on historical data, which may not predict future movements and can lead to overtrading due to frequent signals. o Market conditions can change, rendering patterns less reliable. • Cyclical Analysis: Involves studying economic cycles to determine the optimal timing for investment decisions. This approach is useful for identifying opportunities related to business cycles and economic expansions or contractions. Helps identify buy and sell opportunities based on economic cycles. Useful for timing investments in cyclical industries. o Assumes historical cycles will repeat, which may not occur. o Economic cycles can be disrupted by unforeseen events. Investment Strategies INS uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Page 21 of 50  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. 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. 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 begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Investment Strategies 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. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. 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. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment 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, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate Page 22 of 50  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. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Treasury Inflation Protected/Inflation Linked Bonds: The Risk of default on these bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. 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 increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) 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. Annuities are a retirement product 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 later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long- term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities 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, just as mutual funds do. 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. Private placements carry a substantial risk as they are subject to less regulation that publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. 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 Page 23 of 50  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. 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. • Artificial Intelligence: Advisor utilizes Artificial Intelligence (AI) and/or Machine Learning (ML) technologies in certain aspects of its advisory services. While these technologies aim to enhance efficiency, accuracy, and investment outcomes, their use introduces specific risks that clients should consider. The use of AI in decision-making can result in overreliance on technology, potentially reducing human oversight. Unexpected system malfunctions, algorithmic errors, or misinterpretations of AI-generated insights could adversely affect investment outcomes. Advisor requires human oversight of AI tools. Clients are encouraged to discuss any concerns about AI-related risks. • Alternative Investments: Alternative investment products, including real estate investments, notes and debentures, hedge funds, and private equity are considered highly speculative and involve a high degree of risk. They often engage in leveraging and other speculative investment practices that may increase the risk of investment loss, can be highly illiquid, are not required to provide periodic pricing or valuation information to investors, may involve complex tax structures and delays in distributing important tax information, are not subject to the same regulatory requirements as mutual funds, often charge high fees which may offset any trading profits, and in many cases the underlying investments are not transparent and are known only to the investment manager. Performance can be volatile. Investors could lose all or a substantial amount of their investment. • Business Risk: The measure of risk associated with a particular security. It is also known as unsystematic risk and refers to the risk associated with a specific issuer of a security. Generally speaking, all businesses in the same industry have similar types of business risk. More specifically, business risk refers to the possibility that the issuer of a particular company stock or a bond may go bankrupt or be unable to pay the interest or principal in the case of bonds. • Call Risk: The risk specific to bond issues and refers to the possibility that a debt security will be called prior to maturity. Call risk usually goes hand in hand with reinvestment risk because the bondholder must find an investment that provides the same level of income for equal risk. Call risk is most prevalent when interest rates are falling, as companies trying to save money will usually redeem bond issues with higher coupons and replace them on the bond market with issues with lower interest rates. • Complex Product Risk: Complex Products are sophisticated financial instruments suitable only for experienced investors who understand their terms, strategies, and risks. Most Complex Products reset daily to meet their objectives. This means that if held longer than a day, returns can significantly differ from the target goals, especially in volatile markets or if linked to a volatile index. These products need daily monitoring and are not ideal for a buy- and-hold strategy due to frequent adjustments. They often rebalance daily to adapt to market conditions, leading to frequent trades and higher portfolio turnover. Frequent trading results in higher operating expenses and Page 24 of 50  management fees compared to other funds. Complex Products often use derivatives, which are taxed differently. This means they may not be as tax-efficient as other investment options. • Concentration Risk: Concentrated portfolios are an aggressive and highly volatile approach to trading and investing and should be viewed as complementary to a stable, highly predictable investment approach. Concentrated portfolios hold fewer different stocks than a diversified portfolio and are much more likely to experience sudden dramatic price swings. In addition, the rise or drop in price of any given holding in the portfolio is likely to have a larger impact on portfolio performance, than a more broadly diversified portfolio. • Credit Risk: The risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Cybersecurity Risk: The computer systems, networks and devices used by us and our service providers employ a variety of protections designed to prevent damage or interruption from computer viruses, network and computer failures and cyberattacks. Despite such protections, systems, networks and devices potentially can be breached. Cyberattacks include, but are not limited to, gaining unauthorized access to digital systems for purposes of corrupting data, or causing operational disruption, as well as denial-of- service attacks on websites. Cyber incidents may cause disruptions and impact business operations, potentially resulting in financial losses, the inability of us or our service providers to trade, violations of privacy and other laws, regulatory fines, reputational damage, reimbursement costs and additional compliance costs, as well as the inadvertent release of confidential information. • Currency/Exchange Rate Risk: Currency/Exchange Rate Risk refers to the potential for investment losses due to fluctuations in the exchange rates between currencies. This risk is particularly relevant for investors holding assets in foreign currencies or engaging in international transactions. Exchange rate fluctuations can impact the value of investments when the currency in which they are denominated strengthens or weakens relative to an investor's home currency. This can affect the actual return on investment when converted back to the investor’s domestic currency. • Dependence on Key Personnel: The success of the Underlying Funds will also depend materially upon the active participation of the individuals of the Underlying Managers. There can be no guarantee of the continuing participation of any one or more of these individuals, the loss of whose services could have a material adverse effect on the Underlying Funds. In addition, although the partners and other employees of the Underlying Managers are expected to devote as much time as they believe is necessary to conduct the affairs of the Underlying Funds, generally none of them will be required to devote any particular portion of his or her working time to the affairs of any of the Underlying Funds. These individuals are expected to devote substantial working time to conducting the affairs of the other funds they manage. • Dependence on Underlying Managers: Investments in funds that invest in underlying funds experience reduced control and access to information compared to direct investments. Investors do not have a direct say in the investment decisions or strategies of the underlying funds. They rely on the Underlying Managers to make these decisions, which means they can't influence how funds are allocated or managed. Page 25 of 50  • Derivatives: Investment strategies may cause a client to be exposed to derivatives including instruments and contracts whose value is linked to one or more underlying securities, financial benchmarks, or indices. Derivatives allow an investor to hedge or speculate upon the price movements of a particular security, financial benchmark, index, currency, or interest rate at a fraction of the cost of investing in the underlying asset. The value of a derivative depends largely upon price movements in the underlying asset. • Emerging Markets: The risks of foreign investments typically are greater in less developed countries, sometimes referred to as emerging markets. For example, political and economic structures in these countries may be less established and may change rapidly. These countries also are more likely to experience high levels of inflation, deflation, or currency devaluation, which can harm their economies and securities markets and increase volatility. Restrictions on currency trading that may be imposed by emerging market countries will have an adverse effect on the value of the securities of companies that trade or operate in such • Exchange Traded Fund and Mutual Fund Risk: The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients may incur additional costs associated with ETFs and mutual funds (see Item 5). Consumer Discretionary ETF Shares are listed for trading on NYSE Arca and can be bought and sold on the secondary market at market prices. Although it is expected that the market price of a Consumer Discretionary ETF Share typically will approximate its net asset value (NAV), there may be times when the market price and the NAV vary significantly. Thus, the client may pay more or less than NAV when the Consumer Discretionary ETF Shares are purchased on the secondary market, and the client may receive more or less than NAV when you sell those shares. Although Consumer Discretionary ETF Shares are listed for trading on NYSE Arca, it is possible that an active trading market may not be maintained and Trading of Consumer Discretionary ETF Shares on NYSE Arca may be halted by the activation of individual or market wide "circuit breakers" (which halt trading for a specific period of time when the price of a particular security or overall market prices decline by a specified percentage). Trading of Consumer Discretionary ETF Shares may also be halted if the shares are delisted. • Extraordinary Events: Terrorism and the United States’ involvement in armed conflict may negatively affect general economic fortunes, including sales, profits, and production. An unstable geopolitical climate and continued threats of terrorism and war could have a material effect on general economic conditions, market conditions, and market liquidity (i.e., depressed securities prices and problems with trading facilities and infrastructure). Additionally, a serious pandemic or natural disaster could severely disrupt the global, national, and/or regional economies. A resulting negative impact on economic fundamentals and consumer confidence may increase the risk of default of particular companies and negatively impact our clients. • Fixed Income Risk: When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. Page 26 of 50  • Fixed Income Markets Volatility and Other Risks: Fixed income markets have experienced increased volatility during certain recent periods as investors have considered the effects of Federal Reserve Board policy changes (i.e., with tapering of the Federal Reserve Board’s quantitative easing program and a general rise in interest rates). While volatility in the fixed income markets has subsided at times, such volatility, together with changes in bond market size and structure, are reminders of the possibility of volatility and other risks such as increased redemptions from the Fund. • Foreign Securities Risk: Mutual funds in a client’s portfolio can invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less stringent accounting standards, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Inflationary Risk: The risk that future inflation will cause the purchasing power of cash flow from an investment to decline. • Illiquidity of Investments: There is no public market for any of the investments that will be held by the Funds and it is highly unlikely that one will develop. As a consequence, the Funds’ investments in securities may be illiquid, and the Funds could be prevented from liquidating securities promptly, which may in turn subject the Funds to substantial losses. Illiquidity could also impair the Funds’ ability to distribute withdrawal proceeds to a withdrawing investor in a timely manner. • Interest Rates and Prices; Correction Risks: The price of a debt security generally moves in the opposite direction from interest rates (i.e., if interest rates go up, the value of the bond will go down, and vice versa). In general, securities with longer maturities are more sensitive to these price changes. Additionally, the prices of high yield, fixed-income securities fluctuate more than high quality debt securities. Prices are especially sensitive to developments affecting the company’s business and to changes in the ratings assigned by rating agencies. Prices often are closely linked with the company’s stock prices and typically rise and fall in response to factors that affect stock prices. In addition, the entire high-yield securities market can experience sudden and sharp price swings due to changes in economic conditions, stock market activity, large sustained sales by major investors, a high- profile default, or other factors. Any changes to interest rates could have a significant impact on prices and a client’s account, which could be substantial if the duration levels, if any, of the client’s account are high. See also “Fixed Income Markets Volatility and Other Risks” below. Page 27 of 50  • Interval Fund Repurchase Offers Risk: Advisor can recommend or purchase interval funds. Subject to applicable law, one or more of these funds may place limitations on the percentage of outstanding shares that may be repurchased in each period. If a repurchase offer is oversubscribed, the fund will repurchase the shares tendered on a pro rata basis, and shareholders will have to wait until the next repurchase offer to make another repurchase request. As a result, shareholders may be unable to liquidate all, or a given percentage, of their investment in the fund during a repurchase offer. Some shareholders, in anticipation of proration, may tender more shares than they wish to have repurchased in a quarter, thereby increasing the likelihood that proration will occur. A shareholder may be subject to market and other risks, and the net asset value of shares tendered in a repurchase offer may decline between the repurchase request deadline and the date on which the net asset value for tendered shares is determined. In addition, the repurchase of shares by the fund may be a taxable event to shareholders. • • Interest Rate Risk: The risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. Investment Strategies of Underlying Funds: The investment strategies of the Underlying Funds themselves are generally speculative and may involve significant risks. For example, the Underlying Funds that invest heavily in securities traded publicly on capital markets may be unsuccessful at analyzing these markets profitably, and the Underlying Funds that invest directly in more speculative opportunities may not successfully identify profitable opportunities. • Lack of Investment Discretion in Underlying Funds: The Funds will generally invest in Underlying Funds over which Precision has no investment discretion, and which may themselves invest in highly speculative investments. The success of the Underlying Funds in general is subject to risks related to: (i) the quality of the Underlying Managers and of the companies in which the Underlying Funds invest, (ii) the ability of the Underlying Managers to select successful investment opportunities, (iii) general economic conditions, and (iv) the ability of the Underlying Funds to liquidate their investments. • Legislative Risk: The risk of a legislative ruling resulting in adverse consequences refers to the potential negative impact that new laws, regulations, or changes in existing legislation can have on investments or businesses. Governments may introduce new regulations or modify existing ones, affecting how businesses operate. For example, stricter environmental regulations could increase costs for manufacturing companies, reducing their profitability. Changes in tax laws, such as increased corporate taxes or altered tax incentives, can affect the net income of companies and the after-tax returns for investors. Certain sectors might be more vulnerable to legislative changes. For instance, healthcare reforms can impact pharmaceutical companies, while financial regulations can significantly affect banks and financial institutions. • Limited Access to Underlying Managers: There is no assurance that each Underlying Manager will, as a result of capacity constraints, agree to manage as much of the Funds’ assets as Precision determines to allocate to such Underlying Managers. There also is no assurance that 9 an Underlying Manager will not terminate its relationship with the Funds or return some assets under management. Page 28 of 50  • Liquidity Risk: The possibility that an investor may not be able to buy or sell an investment as and when desired or in sufficient quantities because opportunities are limited. • Margin Transaction Risk: Accounts that use short-term margin loans to buy various securities like swaps, commodities, or derivatives for strategies such as speculation or hedging comes with risks. While margin can enhance returns, it also introduces significant risk, including the possibility of losing more money than initially invested and being subjected to forced sales under unfavorable market conditions. • Market Risk: The risk that the value of securities go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. • Master Limited Partnership (MLP) Risk: MLPs are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. MLPs also face unique risks specific to energy prices, inflation/deflation, regulatory action, interest rate fluctuations and ease of access to capital markets. • Multiple Layers of Expenses: Many Funds utilize a “fund-of-funds” investment strategy, pursuant to which their assets are be invested in the Underlying Funds. Investment management compensation will be charged to the Funds by the Firm and by the Underlying Managers. As a result, such Funds will bear multiple investment management fees, which may include both fees based on assets under management and fees based on capital appreciation, which in the aggregate will generally exceed the compensation which would typically be incurred by an investment with a single portfolio manager. • Mutual Fund Risks: A risk exists that the investment strategies employed by the mutual funds will not meet the stated investment objectives the fund is seeking to obtain. Mutual funds may invest in equities, fixed income, derivatives, and other asset classes; the risks associated with such investments are described in the fund’s prospectus. The performance of a mutual fund may not exactly match the performance of the index or market benchmark that the fund is designed to track due to the mutual fund incurring expenses and transaction costs not incurred by any applicable index or market benchmark. • Pandemic Risk: Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. For example, the novel coronavirus known as COVID-19 involves significant risk of a sustained increase in the volatility of global markets, which volatility could continue for the foreseeable future. Market responses to decisions made by governments and scientists around the world, including measures to contain the spread of the virus, availability of healthcare and treatments, and rolling shutdowns of markets across the globe would negatively impact markets and pose a significant risk of loss to investment principal. The pandemic also poses a risk from a human capital and resource perspective. Page 29 of 50  • Portfolio Inactivity Risk: Advisor maintains procedures for reviewing client portfolios and for making changes to a client’s account holdings. There may be periods where Advisor determines that changes to a client’s portfolio are unnecessary. Clients will remain responsible for paying Advisor ’s fees during all periods and are solely responsible for determining whether the Advisor ’s services remain appropriate for them. • Private Equity Investments: Certain Funds may acquire equity stakes in privately held companies. The success of the Funds’ investments in equity stakes of privately held companies will largely depend in part on the performance and abilities of such companies' controlling shareholders. Because the Funds will not control such companies, the Funds’ ability to exit from such investments may be limited. Additionally, these Funds are likely to have a reduced ability to influence management of such companies. As a result of these factors, Precision may not be in a position to protect the value of a Fund’s investment in a private company. • Real Estate Investment: Such investments may include investing in land zoned for mixed use such as retail shopping, restaurants, schools and universities as well as medical facilities, parks and residential properties. There are various risks to consider such as a lack of public interest and the lack of registration with the SEC or the securities commission of any state or country. In addition, the following, not limited, risks apply: lack of liquidity, zoning restrictions, minimal transparency, changing economic conditions affecting consumer demand, unexpected environmental complications, tenant/resident ability to make rent/mortgage payments (risk of default). Like other Alternative Investments and Limited Partnerships, performance can be volatile. Investments are subject to a complete loss of the principal amount invested with extended time frames before a potential return on capital, if any. In addition, such investments often have concentrated positions that can exaggerate investment risk. Clients with the appropriate risk profile should only consider a portion of their total assets to be held in high risk, volatile positions. • Real Estate Investment Trust Risk: To the extent that a client invests in REITs, it is subject to risks generally associated with investing in real estate, such as (i) possible declines in the value of real estate, (ii) adverse general and local economic conditions, (iii) possible lack of availability of mortgage funds, (iv) changes in interest rates, and (v) environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and losses of self-liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility. • Reinvestment Risk: The risk that falling interest rates will lead to a decline in cash flow from an investment when its principal and interest payments are reinvested at lower rates. • Restrictions on Transferability of Certain Mutual Funds: Certain mutual funds are generally only available through Registered Investment Advisors. If a client terminates Advisor s’ services, they may be unable to transfer their securities to a retail account or to another broker/dealer, and they may be unable to purchase additional shares Page 30 of 50  of those mutual funds they currently own. If they determine to sell their mutual funds, they may be subject to tax consequences. • Settlement Risks: Investment strategies may expose a client to the credit risk of parties with whom Advisor trades (on behalf of the client or the underlying funds) and to the risk of settlement default. Problems of settlement in these markets may affect the net asset value and liquidity of a client’s portfolio or investments in such portfolios. In addition, unlike taking long positions where the risk of loss generally is limited to the value of the investment in the security, the risk of loss of a short position is theoretically unlimited because short positions lose money as the price of the underlying security increases. • Short Selling: Advisor typically will not directly engage in short selling in client accounts. However, Advisor may invest in funds and other securities on behalf of its clients that may sell securities of an issuer short. Short selling by a fund manager can significantly impact the value and volatility of a fund held in a client’s account. • Social/Political Risk: Social and political investment risk refers to the potential for changes in a country's social or political environment to negatively impact the value of investments. These risks can affect the stability and profitability of businesses and, consequently, the performance of investment portfolios. Changes in government, political unrest, or conflicts can create uncertainty and disrupt economic activities. For example, a coup or prolonged protests can lead to instability that affects markets and investor confidence. New rules and/or laws or regulations, or changes to existing ones, can impact industries significantly. For instance, increased environmental regulations may raise costs for companies, while changes in trade policies may affect supply chains and market access. Shifts in societal attitudes or demographic trends can influence market demand or regulatory environments. For example, increased awareness around sustainability might favor green technologies while disadvantaging fossil fuel-based industries. • Tax Harvesting Risk: The trading strategy employed in client accounts is tax harvesting. The intent of this trade is to sell an ETF or mutual fund at a taxable loss and replace that position with a holding whose historical performance and expected future performance are similar, thereby having little impact on the overall strategic allocation, but capturing the tax loss. Because past performance is no indication of future performance, there is potential for the future performance of the replacement position to deviate from that of the initial holding. This type of strategy may also incur an increase in the frequency of trading and amount of transaction costs. • Taxability Risk: The risk that a security that was issued with tax-exempt status could potentially lose that status prior to maturity. Since municipal bonds carry a lower interest rate than fully taxable bonds, the bond holders would end up with a lower after-tax yield than originally planned. • Use of Leverage and/or Derivative Instruments: Many leveraged and inverse funds as well as volatility-linked products use leverage and derivative instruments, such as futures and options contracts, to achieve their stated investment objectives. As such, they can be extremely volatile and carry a high risk of substantial losses. Complex Products are considered speculative investments and should only be used by investors who fully understand the risks and are willing and able to absorb potentially significant losses. Page 31 of 50  • Volatility-Linked Products Risk: Volatility-linked ETPs are designed to track the Chicago Board Options Exchange Volatility Index (VIX) futures. The VIX is a measure of the expected volatility of the S&P 500 index as measured by the implied volatility of options on that index. Volatility ETPs gain exposure to market volatility through futures and/or options contracts on the VIX. Volatility-linked ETPs that seek to maintain a continuous, targeted maturity exposure to VIX futures will either track or hold VIX futures contracts on a rolling basis. They will sell shorter-term contracts or contracts about to expire with contracts that have more distant or deferred maturity dates in order to maintain the desired exposure. The performance of volatility-linked ETPs may be significantly different than the performance of the VIX and the actual realized volatility of the S&P 500 Index. VIX futures contracts are among the most volatile segments of all futures markets. Volatility-linked ETPs may be subject to extreme volatility and greater risk of loss than other traditional ETFs. Types of Investments Investments encompass a wide range of asset classes and financial instruments, each offering distinct features, risk profiles, and potential returns. Each investment type has unique attributes that can align with different financial goals, risk tolerances, and investment horizons. Diversification across these types can help manage risk and optimize potential returns. The following types of investments are those considered by Insight Folios. • Annuities: Retirement 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 later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities 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, just as mutual funds do. • Multi-Year Guaranteed Annuity (MYGA): A MYGA, or Multi-Year Guaranteed Annuity, is a type of fixed annuity that offers a guaranteed interest rate for a specified period, typically ranging from 3 to 10 years. It functions similarly to a Certificate of Deposit (CD), but instead of being offered by a bank, it is provided by an insurance company. Reported quarter-end values may be slightly off due to estimation of values. • Fixed Rate Single Premium Annuity: A fixed rate single premium annuity is an insurance product designed to provide a stable income stream over a specified period in exchange for a one-time upfront payment, known as the single premium. Income distributions can be structured to last for a specific number of years, until death, or for a combination of both. A fixed rate single premium annuity provides a lower-risk investment option than variable annuities or other market-dependent investments. Annual contracts and features vary by state and may not be available in all states. Fixed-rate annuities do not adjust for inflation, meaning the purchasing power of the income payments will decrease over time. Annuities are backed by the financial strength and claims-paying ability of the issuing life insurance carrier. • Cash Positions: Based on a perceived or anticipated market conditions and/or events, certain assets will be taken out of the market and held in a defensive cash position. The firm invests cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government- Page 32 of 50  backed debt instruments. Cash positions are subject to the agreed upon advisory fee as they are managed as part of the overall active investment strategy. The firm does not hold cash positions for an extended period of time. • Cryptocurrency: Cryptocurrencies refer to the actual virtual currency (decentralized digitized money) that allows individuals or entities to transfer funds online without the need for a bank or credit card company, such as Bitcoin, Ethereum, Cardona, and Litecoin. Cryptocurrency is Cryptocurrencies were not designed to be investments and have not been deemed to be a security. They were designed to be mediums of exchange and seen as an alternative to traditional sovereign currencies. Cryptocurrency- related products refer to 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. The SEC, CFTC, NFA, and FINRA have issued investor alerts and advisories on the risks of cryptocurrencies and initial coin offerings (ICOs). These regulators continue to warn investors to keep in mind that actual cryptocurrency and cryptocurrency-related products continue to be speculative and extremely volatile investments. Due to the unregulated nature and lack of transparency surrounding the operations of crypto exchanges, they may experience fraud, market manipulation, security failures or operational problems, which can adversely affect the value of cryptocurrencies and, consequently, the value of the shares of cryptocurrency-related products. • Emerging Markets: The risks of foreign investments typically are greater in less developed countries, sometimes referred to as emerging markets. For example, political and economic structures in these countries may be less established and may change rapidly. These countries also are more likely to experience high levels of inflation, deflation, or currency devaluation, which can harm their economies and securities markets and increase volatility. Restrictions on currency trading that may be imposed by emerging market countries will have an adverse effect on the value of the securities of companies that trade or operate in such countries. • Equity: Investment 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 environment. • Exchange Traded Funds (ETFs): An ETF is a portfolio of securities invested to track a market index similar to an index mutual fund, but the shares are traded on an exchange like an equity. An ETF share price fluctuates intraday depending on market conditions instead of having a net asset value (NAV) that is calculated once at the end of the day. The shares may trade at a premium or discount; and as a result, investors pay more or less when purchasing shares and receive more or less than when selling shares. The supply of ETF shares is regulated through a mechanism known as creation and redemption that involves large, specialized investors, known as authorized participants (APs). Authorized participants are large financial institutions with a high degree of buying power, such as market makers, banks or investment companies that provide market liquidity. When there is a shortage of shares in the market, the authorized participant creates more (creation). Conversely, the authorized participant will reduce shares in circulation (redemption) when supply falls short of demand. Multiple authorized participants help improve the liquidity of a particular ETF and stabilize the Page 33 of 50  share price. To the extent that authorized participants cannot or are otherwise unwilling to engage in creation and redemption transactions, shares of an ETF tend to trade at a significant discount or premium and may face trading halts and delisting from the exchange. The performance of ETFs is subject to market risk, including the complete loss of principal. ETFs also have a trading risk based on cost inefficiency if the ETFs are actively traded and a liquidity risk if the ETFs has a large price spread and low trading volume. In addition, investors buying or selling shares in the secondary market pay brokerage commissions, which may be a significant proportional cost not incurred by mutual funds. • Exchange-Traded Notes (ETNs): An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. However, an ETN is not a mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability to pay. In addition, the trading price of the ETN in the secondary market may be adversely impacted if the issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may or may not be concentrated in a specific sector, asset class or country and may therefore carry specific risks. • 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, although individual bonds may be the best-known type of fixed income security. 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. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. • Hedge Funds and Managed Futures: Hedge and managed futures funds are available for purchase in the program by clients meeting certain qualification standards. Investing in these funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices and the lack of liquidity and performance volatility. In addition, these funds 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. Client should be aware that these funds are not liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the fund, there may be certain repurchase offers made from time to time. However, there is no guarantee that client will be able to redeem the fund during the repurchase offer. Page 34 of 50  • Mutual Funds: Mutual funds are investment vehicles that pool money from multiple investors to invest in a diversified portfolio of stocks, bonds, money market instruments, and similar assets. Open-End Mutual Funds issue an unlimited number of shares and will buy back shares when investors decide to sell. They carry the risk of losing money, and all mutual funds have costs that can lower returns. Closed-End Mutual Funds raise a fixed amount of capital through an initial public offering (IPO) and trade on stock exchanges like stocks. They are not as easily marketable, and investors might not be able to sell their shares easily. To provide some liquidity, these funds may periodically repurchase shares at net asset value. Alternative Investment Funds invest primarily in alternative assets or strategies, which might not be suitable for all investors. These funds involve special risks like those related to commodities, real estate, and derivatives, including issues of leverage and liquidity. • Options: A contract granting the right to either buy or sell a specific amount or value of a particular underlying interest at a fixed exercise price by exercising the option by or before its specific expiration date. The purchase or sale of an option involves the payment or receipt of a premium by the investor and the corresponding right or obligation, as the case may be, to either purchase or sell the underlying security, basket of securities, commodity or other instrument for a specific price at a certain time or during a certain period. Purchasing options involves the risk that the underlying instrument will not change price in the manner expected, so that the investor loses the premium paid. Selling options, on the other hand, involves potentially greater risk because the investor is exposed to the extent of the actual price movement in the underlying security (which could result in a potentially unlimited loss) rather than only the loss of the premium payment received. Prior to buying or selling an option, investors must read a copy of the Characteristics and Risks of Standardized Options, also known as the options disclosure document (ODD). It explains the characteristics and risks of exchange traded options. • Margin Accounts: Client should be aware that margin borrowing involves additional risks. Margin borrowing will result in increased gain if the value of the securities in the account go up, but will result in increased losses if the value of the securities in the account goes down. The custodian, acting as the client’s creditor, will have the authority to liquidate all or part of the account to repay any portion of the margin loan, even if the timing would be disadvantageous to the client. For performance illustration purposes, the margin interest charge will be treated as a withdrawal and will, therefore, not negatively impact the performance figures reflected on the quarterly advisory reports. • Precious Metal: Metals such as Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) 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 Investment Trusts (REITs): A real estate investment trust (REIT) is a company that owns, operates, or finances income-generating real estate. Modeled after mutual funds, REITs pool the capital of numerous investors. This makes it possible for individual investors to earn dividends from real estate investments— without having to buy, manage, or finance any properties themselves. REITs are designed to generate a steady Page 35 of 50  income stream for investors but offer little in the way of capital appreciation. Most REITs are publicly traded like stocks, which makes them highly liquid (unlike physical real estate investments). REITs invest in most real estate property types, including apartment buildings, cell towers, data centers, hotels, medical facilities, offices, retail centers, and warehouses. In general, REITs specialize in a specific real estate sector. However, diversified and specialty REITs may hold different types of properties in their portfolios, such as a REIT that consists of both office and retail properties. • Regulation D Private Placements: Under the federal securities laws, any offer or sale of a security must either be registered with the SEC or meet an exemption. Regulation D under the Securities Act provides a number of exemptions from the registration requirements, allowing some companies to offer and sell their securities without having to register the offering with the SEC. However, a "Form D" must be electronically filed with the SEC after they first sell their securities. Form D is a brief notice that includes the names and addresses of the company’s promoters, executive officers and directors, and some details about the offering, but contains little other information about the company. • Short Sales: A short sale involves the sale of a security that the Client does not own in the hope of purchasing the same security at a later date at a lower price. To make delivery to the buyer, the Client must borrow the security and is obligated to return the security to the lender, which is accomplished by a later purchase of the security. The Client realizes a profit or a loss as a result of a short sale if the price of the security decreases or increases respectively between the date of the short sale and the date on which the Client covers its short position, i.e., purchases the security to replace the borrowed security. A short sale involves the theoretically unlimited risk of an increase in the market price of the security that would result in a theoretically unlimited loss. • Structured Products: Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. Page 36 of 50  • Unit Investment Trust (UIT): An investment company that offers a fixed, unmanaged portfolio, generally of stocks and bonds, as redeemable "units" to investors for a specific period of time. It is designed to provide capital appreciation and/or dividend income. UITs can be resold in the secondary market. A UIT may be either a regulated investment corporation (RIC) or a grantor trust. The former is a corporation in which the investors are joint owners; the latter grants investors proportional ownership in the UIT's underlying securities. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Salvatore Bonetti is a registered representative and an independent insurance agent. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a potential conflict of interest, as commissionable products create incentives that conflict with the fiduciary duties of a registered investment adviser. To mitigate this conflict, Insight Folios has implemented specific procedures including: (1) thorough review of all recommendations involving commissionable products, (2) documentation of the rationale for each recommendation, and (3) regular supervision and monitoring of sales practices. Insight Folios maintains strict policies to ensure it always acts in the best interest of the client, including when recommending commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of Insight Folios in such individual’s outside capacities. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Page 37 of 50  Neither INS nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Conflicts of Interests Charles Buddy Bowers Jr., Kenneth Lee Huffman, Bruce Romagnoli, Kevin Wray, Paul L. Durso, Ashok S Ramji, David Kyle Morgan, Sean Richard Sparkman, Ryan McNeill, Niki Waters Erb, Salvatore Bonetti, Larry Gene McCabe, Sheila Rene Madrigal, Zachary Poitra and Charles Dingman are independent licensed insurance agents, and from time to time, will offer clients advice or products from those activities. Paul L. Durso is owner of Durso Capital Management Co. an insurance agency. Kenneth Lee Huffman is the owner of Huffman Financial an insurance agency. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. INS always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of INS in connection with such individual's activities outside of INS. Paul Durso pursues sales, marketing, design, and coaching through the Planning Made Simple Program and the Simplicitree® software to investment advisers. These are offered on a subscription basis. Planning Made Simple is an educational program that is offered to clients of INS, but clients have the right to decide whether or not to participate in this program. Simplicitree is a financial planning software that is used with INS clients. Simplicitree points to client future needs without pointing specifically to an investment option. Investment options can be shown as beneficial or not beneficial through the software calculations. There are no additional fees to the client for the use of this software. INS has two sub-advisory relationships, Daniel Financial Group and Charter Financial Group, where Insight Folios invests AUM for these firms. Kenneth Lee Huffman is President of The Perimeter Group, Inc. The Perimeter Group, Inc. provides diabetic medical supplies and was formed in July of 1997. Products from The Perimeter Group are not offered to clients of INS. Kenneth Lee Huffman is a captive insurance manager and president of Captive Nation, Inc. Captive Nation, Inc. creates and manages captive insurance companies. Bruce Romagnoli is the owner of B&B Income Tax Services, LLC. From time to time, he will offer clients services from those activities. Clients always have the right to decide whether or not to utilize the services of any representative of Insight Folios in such individual’s outside capacities. Larry Gene McCabe is the founder/owner of Aloha Life & Retirement, Inc Page 38 of 50  Zachary Bram Poitra works as a Life Coach. Charles Halbert Dingman III is the owner of Charlie Dingman Fine Art. Charles Halbert Dingman III is the managing director of Redwood Tax Specialists. Charles Halbert Dingman III is the owner of Dingman Wealth Strategies. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections INS may direct clients to third-party investment advisers. INS will be compensated via a fee share from the advisers to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that INS has an incentive to direct clients to the third-party investment advisers that provide INS with a larger fee split. INS will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. INS will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where INS is recommending the adviser to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics INS has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. INS's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests INS does not recommend that clients buy or sell any security in which a related person to INS or INS has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of INS may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of INS to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives Page 39 of 50  profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. INS will always document any transactions that could be considered as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities to clients resulting in representatives profiting off From time to time, representatives of INS may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of INS to buy or sell securities before the or after recommending securities recommendations they provide to clients. Such transactions may create a conflict of interest; however, INS will never engage in trading that operates to the client’s disadvantage if representatives of INS buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on INS’s 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. Clients will not necessarily pay the lowest commission or commission equivalent, and INS 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 INS's research efforts. INS will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. INS recommends Charles Schwab & Co., Inc. Charles Schwab & Co., Inc. provides INS with access to Charles Schwab & Co., Inc.’s institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Charles Schwab & Co., Inc. includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For INS client accounts maintained in its custody, Charles Schwab & Co., Inc. generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. or that settle into Charles Schwab & Co., Inc. accounts. Charles Schwab & Co., Inc. also makes available to INS other products and services that benefit INS but may not benefit its clients’ accounts. These benefits may include national, regional or INS specific educational events Page 40 of 50  organized and/or sponsored by Charles Schwab & Co., Inc. Other potential benefits may include occasional business entertainment of personnel of INS by Charles Schwab & Co., Inc. personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist INS in managing and administering clients’ accounts. These include software and other technology (and related technological training) 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 INS’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of INS’s accounts. Charles Schwab & Co., Inc. also makes available to INS other services intended to help INS manage and further develop its 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, Charles Schwab & Co., Inc. may make available, arrange and/or pay vendors for these types of services rendered to INS by independent third parties. Charles Schwab & Co., Inc. may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to INS. INS is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. 1. Research and Other Soft-Dollar Benefits While INS does not maintain a formal soft dollars program for third-party services, INS may receive certain research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). The specific types of benefits received include [list specific benefits received]. INS may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and INS does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. INS benefits by not having to produce or pay for the research, products or services, and INS will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that INS’s acceptance of soft dollar benefits may result in higher commissions charged to the client. Advisor does not receive soft dollars; however, the firm receives support services and/or products from our custodians to better monitor and service program accounts maintained on behalf of Advisor ’s clients. These support services and/or products are received without cost, at a discount, and/or at a negotiated rate, and may include the following: • investment-related research • compliance and/or practice management- related publications consulting services • • pricing information and market data • software and other technology that provide access to client account data Page 41 of 50  • attendance at conferences, meetings, and other educational and/or social events computer hardware and/or software • • • • marketing support • • other products and services used by Advisor in furtherance of its investment advisory business operations custody of securities trade execution clearance and settlement of transactions Page 42 of 50  2. Brokerage for Client Referrals INS receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use INS permits Clients to direct it to execute transactions through a specified broker- dealer. Clients must refer to their advisory agreements for a complete understanding of how they may be permitted to direct brokerage. If a client directs brokerage, the client will be required to acknowledge in writing that: (1) the Client’s direction with respect to the use of brokers supersedes any authority granted to INS to select brokers; (2) such direction may result in higher costs and less favorable execution; and (3) the client understands and accepts these consequences of directed brokerage. this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the client may be unable to participate in block trades (unless INS is able to engage in “step outs”) and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If INS buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, INS would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. INS would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Cash Sweep Program Investment portfolios often include a cash allocation to maintain liquidity, manage risk, and provide funds for opportunistic investments. Cash allocations can serve as a buffer against market volatility and ensure that funds are readily available for future investment opportunities or withdrawals. Sweep programs automatically transfer uninvested cash from a brokerage account into a money market fund or other short-term investment vehicle at the custodian. This process is automated and occurs regularly, often at the end of each business day. While the cash is held in Page 43 of 50  the sweep account, it earns interest. This ensures that even idle cash is generating some return, albeit typically lower than other investment options. By automating the movement of cash, sweep programs reduce the need for manual transfers, saving time and minimizing the risk of human error in managing cash balances. Sweep accounts provide quick access to cash for reinvestment or withdrawals, enhancing liquidity management within the portfolio. Minimizing manual cash management tasks reduces administrative burdens for both the investor and the advisor, allowing them to focus on strategic investment decisions. Sweep programs often offer lower interest rates compared to other short-term investments like high-yield savings accounts or CDs. This is due to the liquidity and convenience they provide. While convenient, the lower interest rates mean that investors can miss out on higher returns if cash is kept in the sweep account for extended periods. Advisor uses sweep programs strategically to manage cash flows within a portfolio, ensuring that cash is readily available for investment opportunities without sacrificing significant returns. Sweep accounts can also be used to facilitate regular transactions, such as automatic withdrawals for living expenses or periodic investments in other asset classes. While sweep programs offer convenience and liquidity, they require careful consideration as part of an overall investment strategy. Advisors and clients should weigh the benefits of liquidity and automation against the potential for higher returns through alternative cash management strategies. The research products and services provided by a Custodian may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making. These support services provided by a Custodian to Advisor are based on the overall relationship between Advisor and the Custodian. It is not the result of soft dollar arrangements or any other express arrangements with the Custodian that involves the execution of client transactions as a condition to the receipt of services. • Advisor will continue to receive the services regardless of the volume of client transactions executed with the Custodian. • Clients do not pay more for services as a result of this arrangement. • There is no corresponding commitment made by the Advisor to the Custodian or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. Although the non-soft dollar investment research products and services that may be obtained by our firm will generally be used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. As a result of receiving  the services Advisor may have an incentive to continue to use or expand the use of the Custodian’s services. Our firm examined this potential conflict of interest when we chose to enter into the relationship and we have determined that the relationship is in the best interest of our clients and satisfies our fiduciary obligations, including our duty to seek best execution. Brokerage Referrals Advisor does not receive any compensation from any third party in connection with the recommendation for establishing a brokerage account. Transaction Fees The Custodian charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). The Custodian enables Advisor to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. The Custodian’s commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by the Custodians may be higher or lower than those charged by other custodians and broker/dealers. Best Execution Both advisers and broker/dealers have a fiduciary obligation to obtain the best execution of securities transactions when they arrange for or execute trades on behalf of clients. The origins of the best execution duty predate the federal securities laws and may be traced to the common law agency obligations of undivided loyalty and reasonable care that an agent owes to his or her principal.2 Advisers and broker/dealers are not obligated to obtain the lowest possible commission cost, but rather should seek to obtain the most favorable terms for a customer transaction reasonably available under the circumstances. In the context of best execution, the primary focus is on obtaining the most favorable outcome for the client, not merely minimizing costs. This approach considers the overall quality and efficiency of the transaction, including several key factors: • Value of Research Provided: The research offered by a broker/dealer can significantly impact the quality of investment decisions. Comprehensive and insightful research can lead to better-informed strategies, which may justify higher costs if the research enhances investment returns. • Execution Capability: This refers to the broker's ability to effectively and swiftly execute trades. A broker with advanced technology and systems can ensure that trades are executed 2 See Hall v. Paine, 112 N.E. 153, 158 (Mass. 1916) ("broker's obligation to his principal requires him to secure the highest price obtainable"). See also Restatement (Second) Agency § 424 (1958) (agent must "use reasonable care to obtain terms which best satisfy the manifested purposes of the principal."); Newton v. Merrill, Lynch, Pierce, Fenner & Smith, Inc., et al., 135 F.3d 266 (3d Cir. 1998).  promptly and at prices that closely match the client's expectations, which is crucial in fast- moving markets. • Commission Rates: While commission rates are important, they are not the sole consideration. Lower commissions might not always equate to better execution if the broker lacks in other areas, such as research or execution speed. • Responsiveness: The ability of the broker/dealer to respond quickly to client needs and market changes is vital. A responsive broker can adapt to new information or changes in client instructions, enhancing the overall service quality. Thus, while competitive rates are sought to benefit all clients, the totality of the broker/dealer's services is weighed to ensure that the client's interests are best served. This means that the lowest commission rate might not always be chosen if it compromises other aspects of the transaction that could ultimately affect the client's investment returns. Aggregation and Allocating Trades The primary goal when placing orders for buying and selling securities on behalf of client accounts is to achieve the most favorable net results. This means that the advisor aims to secure the best possible outcome for clients by considering several key factors: • Price: The priority is to obtain the best possible price for the securities being bought or sold. This involves considering current market conditions and potential price fluctuations. • Size of Order: The size of the transaction can influence the price and execution. Larger orders might need to be handled differently to avoid impacting the market price significantly or ensure the entire order is filled. • Difficulty of Execution: Some trades might be more complex or difficult to execute due to market conditions, the nature of the security, or liquidity issues. Advisor must consider these factors to ensure the trade can be executed effectively. Aggregating or bunching securities involves combining multiple client orders into a single transaction. This practice is often used to streamline the trading process and potentially achieve better pricing through the economies of scale. However, there are inherent risks and considerations, especially in the context of illiquid securities or volatile market conditions: • Potential for Less Favorable Prices: When multiple orders are aggregated, the resulting larger order might receive a less favorable price compared to executing smaller, individual transactions. This is particularly relevant for illiquid securities, where the market may not have enough buyers or sellers to accommodate a large trade without affecting the price significantly. • Market Impact: Bunching large orders can drive the market price up or down, depending on whether the order is a buy or sell order. This impact is more pronounced in volatile  markets where prices can change rapidly, and large trades can exacerbate these fluctuations. • Execution Timing: The timing of a bunched order's execution might not align perfectly with the optimal timing for each individual client involved. This could lead to deviations from the ideal price each client might have achieved had their order been executed separately. • Allocation of Shares: After execution, the aggregated order must be allocated fairly among participating client accounts. The allocation process must be handled equitably to ensure that all clients are treated fairly, especially if the order is not filled completely. • Risk Management: In volatile markets, large aggregated trades can introduce additional risks, as the market conditions can change quickly, affecting the execution price and overall strategy. Despite these potential drawbacks, aggregation can still offer benefits, such as reducing transaction costs and increasing the likelihood of order fulfillment. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for INS's advisory services provided on an ongoing basis are reviewed at least quarterly by the assigned investment adviser representative, with regard to clients’ respective investment policies and income needs as indicated by their Simplicitree analysis. Simplicitree is a financial planning software that is used with INS clients. Simplicitree points to client future needs without pointing specifically to an investment option. Investment options can be shown as beneficial or not beneficial through the software calculations. There are no additional fees for the use of this software. All financial planning accounts are reviewed upon financial plan creation and plan delivery by the assigned investment adviser representative. There is only one level of review for financial planning, and that is the total review conducted to create the financial plan. 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 client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, INS’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of INS's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. 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 (Includes Sales Awards or Other Prizes) Compensation is received from Third-Party Managers in the form of solicitor/referral fees. B. Compensation to Non – Advisory Personnel for Client Referrals INS does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Industry Professionals When it serves the best interests of the client, Advisor recommends the services of other professionals, such as attorneys or accountants, for non-investment-related needs. These introductions can be valuable in providing clients with comprehensive support and expertise beyond the Advisor's direct offerings, ensuring clients receive well-rounded assistance in various aspects of their financial and legal matters. Introducing clients to other professionals creates a conflict of interest because the referred professional might feel an implicit obligation to reciprocate by referring potential new clients back to the Advisor. This could influence recommendations, prioritizing professionals likely to reciprocate rather than solely considering the client's best interests.  Clients are under no obligation to use the services of a recommended professional. They are free to seek advice and services from other professionals of their choosing. Recommendation are merely a suggestion based on perceived quality and suitability; clients retain full discretion over whether to engage with the suggested professionals. If a client decides to engage with a referred professional and a dispute arises, the client’s recourse is solely against the engaged professional. Advisor does not assume responsibility for the actions or outcomes of services provided by third- party professionals. Clients should conduct their own due diligence and ensure they are comfortable with the terms and conditions proposed by the referred professional. Additional Compensation Advisor can receive economic benefits from sources other than the client for providing advisory services. These benefits can take various forms, including sales awards, gifts, meals, or entertainment such as tickets to concerts, shows, or sporting events. Here's a more detailed explanation: • Sales Awards: Recognitions or bonuses given for achieving certain targets or performance metrics, often provided by product sponsors or financial institutions. • Gifts: These can range from small tokens of appreciation to more significant items, potentially offered by business partners or vendors. • Meals & Entertainment: Occasional meals, invitations to events, or tickets to entertainment activities provided by third-party entities, such as product sponsors or other financial service providers. These economic benefits create a conflict of interest, as they can unconsciously influence decisions regarding the selection of products and/or services. For instance, an advisor might be more inclined to recommend products from a sponsor that offers more generous incentives. This influence can affect the objectivity of recommendations; however, Advisor has a fiduciary duty to act in a client’s best interest. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, INS will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion INS provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Clients with discretionary accounts will execute a limited power of attorney to  evidence discretionary authority. Where investment discretion has been granted, INS generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Clients may, but typically do not, impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Item 17: Voting Client Securities (Proxy Voting) INS 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. While INS does not provide specific advice on proxy voting decisions, clients may contact INS with general questions about proxy materials they receive, and we can direct them to appropriate resources for additional information. Item 18: Financial Information A. Balance Sheet INS neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither INS nor its management has any financial condition that is likely to reasonably impair INS’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years INS has not been the subject of a bankruptcy petition in the last ten years.