Leigh Baldwin & Co., LLC

PART 2A Form ADV Firm Brochure March 2026 ITEM 1 COVER PAGE i This Brochure provides information about the qualificationsand business practices of Leigh Baldwin & Co., LLC. If youhave any questions about the contents of this Brochure,please contact us at 1-800-659-8044. The information in thisBrochure has not been approved or verified by the UnitedStates Securities and Exchange Commission or by any statesecurities authority.Leigh Baldwin & Co., LLC is a registered investment advisor.Registration of an Investment Advisor does not imply anylevel of skill or training. The oral and written communicationsof an advisor provide you with information about which youdetermine to hire or retain an advisor.Additional information about Leigh Baldwin & Co., LLC also isavailable on the SEC’s website at www.adviserinfo.sec.gov.Please note that registration as an investment advisory firmdoes not imply a certain level of skill or training.Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comLEIGH BALDWINADVISORY ITEM 2 MATERIAL CHANGES ii In early 2026, the firm expanded its custodial relationships by adding Altruist Financial LLC, an unaffiliated SEC-registered broker-dealer and FINRA/SIPC member. Custody, clearing and execution services are provided byAltruist Financial LLC as a self-clearing broker dealer. Leigh Baldwins & Co.'s advisory clients may establishbrokerage accounts through Altruist. Leigh Baldwin & Co maintains an institutional relationship with Altruistwhereby Altruist provides certain custodial and operational services to the firm, including a fully digital accountopening process, a variety of available investments, and integration with software tools that can benefit the firmand its clients. Leigh Baldwin Advisory is not affiliated with Altruist. Altruist does not supervise Leigh Baldwins'Advisors, its agents, activities, or its regulatory compliance.As a result of this new relationship, the firm will discontinue use of Folio/Goldman Sachs as a potential custodian inthe second quarter of 2026.Currently a full copy of our brochure may be requested by contacting Leigh Baldwin at 1-800-659-8044 orleigh@leighbaldwin.com. Our brochure is also available on our website www.leighbaldwinadvisory.com free ofcharge.Additional information about Leigh Baldwin & Co., LLC is also available via the SEC’s websitewww.adviserinfo.sec.gov. The SEC’S website also provides information about any persons affiliated with LeighBaldwin & Co., LLC who are registered, or are required to be registered, as investment advisor representatives ofLeigh Baldwin & Co., LLC.Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.com ITEM 3 TABLE OF CONTENTS iii Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comItem 1Item 2Item 3Item 4Item 5Item 6Item 7Item 8Item 9Item 10Item 11Item 12Item 13Item 14Item 15Item 16Item 17Item 18Cover PageMaterial ChangesTable of ContentsAdvisory BusinessFees and CompensationPerformance-Based Fees and Side-by-Side ManagementTypes of ClientsMethods of Analysis, Investment Strategies, and Risk of LossDisciplinary InformationOther Financial Industry Activities and AffiliationsCode of EthicsBrokerage PracticesReview of AccountsClient Referrals and Other CompensationCustodyInvestment DiscretionVoting Client SecuritiesFinancial Informationiiiiii4610101011111213141415151616 ITEM 4 ADVISORY BUSINESS 4 Leigh Baldwin & Co., LLC (LBA) is an SEC Registered RIA as well as a FINRA registered Broker Dealer. We have beenregistered with the SEC as an RIA since June of 2008, and prior to that as New York State RIA since May of 2000.We have been registered as a FINRA Broker Dealer since August of 1995. The firm is owned by Mr. Leigh D. Baldwinand Leigh Baldwin & Co., Inc, with Leigh D. Baldwin being the beneficial owner of the corporation.Investment Advisors of Leigh Baldwin& Co., LLC may act as a solicitor for other approved SEC registered RIA’s, aswe allow properly registered advisors to solicit business on behalf of these other RIA Firms. This referralarrangement with an outside RIA allows our advisor to be compensated by way of a solicitor fee from thatcompany based on assets under management. Please refer to Item 5 on Compensation. The client signs theirmanagement agreement and receives both our ADV as well as their ADV; the outside investment manager makesall investment decisions on behalf of the client under the terms and conditions in their management agreements.Investment Advisors of Leigh Baldwin & Co., LLC manage discretionary account portfolios based upon the client'srepresentations as to their financial capabilities and risk capacity. They recommend, buy, sell, and monitorinvestments with the aim of creating diversified portfolios to meet the client’s investment objectives. At timesthere may be positions that are held short-term or traded. After discovery meetings, and periodic reviews, tradingfor discretionary accounts is usually done without further consultation.We do not prepare or issue special reports, analyses, charts, graphs, formulas, or other devices which clients mayuse to evaluate securities not included in any services described above. We do not furnish advice to clients on anymatters outside securities on other than an incidental basis, nor do we furnish investment advice in any mannernot described above.Financial Planning and Consulting Services (Stand-Alone)We view financial planning as an important aspect of the advisor/client relationship and access to financialplanning software is typically provided to advisory clients of the firm (as part of the on-going fees). We may also beengaged to provide financial planning and/or consulting services (including investment and non-investmentrelated matters, estate planning, insurance planning, etc.) on a stand-alone separate fee basis. The planning andconsulting fees are negotiable,but generally start at $4,000 annually for a stand-alone comprehensive financialplan. An advisor may provide financial planning services on an hourly rate basis, depending upon the level andscope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging the advisor toprovide planning or consulting services, clients are generally required to enter into a Financial Planning andConsulting Agreement with the advisor setting forth the terms and conditions of the engagement (includingtermination), describing the scope of the services to be provided, and the portion of the fee that is due from theclient prior to commencing services.If requested by the client, the advisor may recommend the services of other professionals for implementationpurposes, including certain representatives of LBA in their individual capacities as dually registered representativesand/or in their capacities as licensed insurance agents. The client is under no obligation to engage the services ofany such recommended professionals. The client retains absolute discretion over all such implementationdecisions and is free to accept or reject any recommendation. Please note, if the client engages any suchrecommended profession, and a dispute arises thereafter relative to such engagement, the client agrees to seekrecourse exclusively from and against the engaged professional. Please also note, it remains the client’sresponsibility to promptly notify LBA if there is ever any change in their financial situation or investment objectivesfor the purpose of reviewing, evaluating, or revising previous recommendations and/or services.The Fidelity Management Account Xchange (FMAX)This program allows your IAR to provide you advisory services by using a third-party advisory service. Dependingon the advisory program selected, the day-to-day management of the advisory account may be performed by theIAR, a third-party manager, or a combination of the two. This is a tri-party investment advisory platform and issponsored by Fidelity Institutional Wealth Advisers, LLC (“FIWA”) and the clearing custodial firm, National FinancialLeigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.com 5 Services, LLC (NFS). A custodian is the entity that holds your securities and other investments on behalf of LBA. TheFMAX program consists of an extensive range of investment advisory services, including Separately ManagedAccounts, Fund Strategist Portfolios of Mutual Funds and ETFs, Unified Managed Accounts, and an Advisor ModelManagement Program. Clients who select the FMAX program and one of the following programs: SeparatelyManaged Accounts, Fund Strategist Portfolios of Mutual Funds and ETFs, Unified Managed Accounts will alsoreceive FIWA Form ADV Part 2A, which provides greater detail regarding the program sponsor. Each of theseprograms has distinct fees and charges such as a program, firm and intermediary fee and are outlined in theStatement of Investment Selection (SIS) that is provided to you prior to investing as are the minimum fee amountsby program type. In certain instances, additional costs may be incurred such as an asset-based surcharge formutual funds that are deemed by the Custodian to be non-revenue paying. Your IAR can discuss the features ofeach program with you so that you may determine your preferred cost option that best suits your investmentstyle.The FMAX program charges a fee based on a percentage of the assets in a program account. This fee is a bundledfee for services such as investment advice, including portfolio management, research, custodial services, reportingand trading and execution. This type of fee is not based directly on the amount of transactions in a client’s accountbut rather the fee is calculated based on the asset value of the Client’s account. Accordingly, if there is little or notrading activity in the account, it is possible that a Client may pay more in advisory fees than he or she would havein commission charges if the account was a brokerage account, depending upon the number of trades that occurin an account from year to year. Each Program generally includes investment management, custody, reporting,performance-monitoring, and trade execution services. LBA acts as an intermediary to the FIWA program.Fees paid to the Third-Party Manager generally range from .25% to .50% and are applied as a weighted averagebased on each sleeve’s allocation relative to the total portfolio. The FMAX structure offers Advisors and Clients theability to bundle multiple model portfolios and investment strategies together in one account, the Client could paymore for an investment strategy in this program. This means that they may pay more for this program than theywould otherwise pay for the strategy in one of LBC’s other fee programs. LBA retains .01%-.03% of all AUM on thisFIWA platform in addition to any other fees discussed in this brochure.Altruist LLC Model MarketplaceLBA participates in the Model Marketplace [and/or uses tax management tools] of Altruist LLC (“Altruist”), an SEC-registered investment adviser and affiliate of Altruist Financial LLC. Through the Model Marketplace, LBA hasaccess to model portfolios including Altruist generated portfolios and Third-Party Portfolios, to assist it inmanaging or advising client accounts. LBA also has the ability to create custom model portfolios, and has access totax management tools for use with Altruist generated portfolios, Third-Party Portfolios, and custom modelportfolios, to assist LBA in managing or advising its client accounts. Altruist and its affiliates do not act asinvestment advisers or fiduciary to LBA clients. LBA is responsible for suitability of all investment decisions andtransactions for client accounts subscribed to model portfolios through the Model Marketplace.Altruist One ProgramLBA may subscribe select client accounts to participate in the Altruist One Program (“Altruist Oneˮ) offered byAltruist Corp, the parent company of Altruist Financial LLC, a SEC registered broker dealer and FINRA/SIPCmember and Altruist LLC, an SEC-registered investment adviser (collectively, “Altruistˮ). Under this program, LBAmay enroll client account(s) into a bundled subscription offering that provides certain benefits in exchange for amonthly fee.The monthly fee is absorbed by LBA. The cost and fee calculation methodology are detailed in the Altruist OneTerms of Use, which is available on www.altruist.com/legal.Benefits provided under this program may include:Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comHigher interest rates on cash balances.Waived or discounted transaction fees for mutual funds, fixed income, and other securities.Waived or discounted fees for automated tax management tools.Waived or discounted fees to access model portfolios.Only clients enrolled in Altruist One will have access to these benefits. Altruist One may not be suitable for all clients ITEM 5 FEES AND COMPENSATION Value of Managed Assets Annual Fee 6 of LBA. The Firm determines eligibility based on a review of account characteristics and whether the platform’sfeatures are reasonably expected to provide a meaningful benefit to the client. Accounts that consist primarily ofqualified assets or that maintain minimal cash balances may not receive meaningful benefit from the platform’stax‐aware or cash management features and therefore may not be placed on the Altruist One platform.Assets Under ManagementAs of December 31, 2025, we manage $290,629,757.00 in discretionary assets. We do not manage accounts on anon-discretionary basis.Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.com$0 to $250,0001.55%$250,001 to $500,0001.50%$500,001 to $1,000,0001.25%over $1,000,0011.00%Traditional LBA Managed AccountCompensation for advisory services is a flat percentage based on assets undermanagement computed using theclosing account balance on the last business day of the previous quarter. Maximum Fees in a traditional managedaccount are as follows; all fees are subject to negotiation. Total ticket charges (commissions and service fees) andother fees may also apply, see item 12 brokerage practices. Management fees will be deducted or billed quarterlyfour times per year.Hybrid LBA AccountsIn our legacy negotiated hybrid models, stock commissions and other fees may be used in conjunction with amanagement fee. Management fees would not be charged on the value of these positions that have incurredcommissions. Typically, management fees in this type of arrangement are assessed on Mutual Fund positions.Accounts are billed on the same schedule as Traditional LBA Managed Accounts.Use of Altruist Financial LLC as a CustodianIn addition to National Financial Services LLC, the Firm makes Altruist Financial LLC (“Altruist”) available as aqualified custodian for certain managed accounts. Altruist is an unaffiliated SEC‐registered broker‐dealer andFINRA/SIPC member that provides custodial, trading, and account administration services. Clients may be offeredthe ability to custody assets at Altruist based on account characteristics, client preferences, and the Firm’sdetermination of the most appropriate custodial platform for the client’s needs. The management fee will betiered according to AUM, this means that as your assets exceed a certain level, subsequent assets over that levelwill be charged a lower annual percentage rate, but assets below that level will continue to be charged the originalannual percentage rate. The fee is calculated based on the average daily net asset value of the account, billedmonthly in arears.Altruist LLCʼs Model Marketplace fees and tax management tool fees – each of which range between 0.00% and1.00% and are listed in the Altruist Fee Schedule available at www.altruist.com/legal – are automatically deductedfrom the Advisorʼs house account or, according to the instruction of LBA. Value of Managed Assets Annual Fee Value of Managed Assets Annual Fee FMAX Program Minimum Annual Fee 7 $0 to $250,0001.55%$250,001 to $500,0001.50%$500,001 to $1,000,0001.25%over $1,000,0011.00%Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comAltruist One PlatformCertain accounts custodied at Altruist may be eligible for participation in the Altruist One platform. Altruist Oneprovides enhanced account features, which may include tax‐aware portfolio management tools and enhancedcash management options. The Altruist One platform results in an additional platform fee to the Firm ofapproximately 0.12% of assets under management. The Firm does not charge clients an additional advisory fee forparticipation in the Altruist One platform and absorbs this cost. As a result, a client’s advisory fee schedule is notincreased solely because an account is placed on the Altruist One platform.Tiered Fee Accounts through Fidelity Managed Account Xchange (FMAX)Available as an addendum to our traditional management agreement. The client’s management fee will be billedmonthly according to the Statement of Investment Selection (SIS) through the FMAX program. The fee will betiered according to AUM, this means that as your assets exceed a certain level, subsequent assets over that levelwill be charged a lower annual percentage rate, but assets below that level will continue to be charged the originalannual percentage rate. The fee is calculated based on the average daily net asset value of the account, billedmonthly in advance. FMAX is structured by Fidelity Institutional Wealth Advisor LLC (FIWA) as a wrap program thatbundles investment advice, transaction services, custody and other administrative expenses for a fee disclosed inthe SIS which ranges from .10% to .22%. LBA, as an intermediary to this program, may charge additional fees forservices it performs in addition to the program fee (see Section 5, page 8 for a description of these possible fees; ifpart of this program, please refer to FIWA Form ADV “Other Issues Related to Fees”) FIWA structures the wrapaccount, LBA may utilize this as part of their managed program as the advisor intermediary.Management Fee and Minimum Annual Fee Schedules:$0 to $250,0001.55%$250,001 to $500,0001.50%$500,001 to $1,000,0001.25%over $1,000,0011.00%Select Fund Strategist Portfolios (SFSP)$50.00Advisor Model Management (AMM)$75.00Fund Strategist Portfolios (FSP)$150.00Separately Managed Accounts (SMA)$150.00Unified Managed Accounts (UMA)$350.00 Value of Managed Assets Annual Fee 8 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comIn SFSP, FSP, SMA, and UMA models an outside investment manager will be paid, and this will not be at anadditional cost to the client over their agreed upon management fee subject to the minimums and maximumscovered above.Dollar Investment Club (DINC)Compensation for advisory servicesis calculated based on the average daily net asset value of the account, billedmonthly in arears. Maximum Fees in a DINC managed account are as follows; all fees are subject to negotiation.$0 to $499,9990.95%over $500,0000.75%Each managed program described above may utilizefee structures that differ in the following ways:Non-Wrap Fee Programs (Traditional, Hybrid and DINC)Non-wrap fee programs assess trade execution costs that are in addition to the investment advisory fees. Wecharge an investment advisory fee for our advisory services and other fees are charged for each transaction(purchase, sale, or exchange.) For purposes of clarification, commissions and/ or service fees are considered oneand the same and are often referred to as “ticket charges”. Leigh Baldwin & Co., LLC has a conflict of interest inoffering non-wrap accounts custodied through National Financial Services due to the receipt of additionaltransaction-based ticket charge revenue, received by us in our capacity as a broker-dealer. Continue to review thissection for more details on fees.Integrated Wrap Fee Services (FMAX and Altruist)The Firm does not sponsor or participate in a traditional wrap fee program. Clients are charged a separate advisoryfee for investment management services, and brokerage, custodial, and other transaction‐related costs may becharged separately unless otherwise disclosed. The Firm utilizes custodial platforms that integrate brokerage,custody, and account administration services. These integrated services are provided by unaffiliated custodiansselected by the Firm based on client needs and account characteristics.Although the Altruist One platform integrates certain services commonly associated with wrap fee programs,clients do not pay a bundled or wrap fee for participation in the platform. Clients continue to pay the Firm’sadvisory fee as disclosed in Item 5, and standard custodial or transaction‐related charges may still apply. TheAltruist One platform results in an additional platform fee to the Firm. The Firm absorbs this cost and does notcharge clients an additional fee for participation in the platform.This fee program is defined as an advisory program in which a client pays a single, specified fee for portfoliomanagement services and trade execution. FMAX offered through FIWA is structured as a wrap program, and LBAacts as an intermediary to offer this account to the client. We receive a portion of the investment advisory fee youpay when you participate in this program. Generally, this type of account is less expensive for actively tradedaccounts. For accounts with little or no trading activity, this type of program may not be suitable because the feecould be higher than fees in a traditional brokerage account. Clients utilizing an account on the FMAX platform willreceive FIWA’s Form ADV that covers the WRAP relationship they provide, if applicable. As an intermediary to theFMAX program, LBA will charge accounts for IRA yearly fees, paper statement and confirmation fees, combinedcommissions and service fees on more than 75 trades per calendar year if in the Advisor Model Management FMAXprogram (based on the program).The Firm does not sponsor a wrap fee programClients are not charged a single bundled fee for advisory, brokerage, and custodial servicesBrokerage and custodial services are provided by unaffiliated third‐party custodiansParticipation in custodial platforms and features is determined based on account characteristics and client needs 9 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comAdditional information regarding fees and conflicts of interest associated with custodial platform selection isdescribed in this section (Fees and Compensation) and Item 12 (Brokerage Practices).You should evaluate the total cost for participating in a particular advisory program in consultation with your IAR.For Managed Accounts that are custodied at our Broker Dealers clearing firm, National Financial Services., LLC, themanagement agreement between the client and Leigh Baldwin & Co., LLC will be on file that allows a fee debitfrom the clients account at the beginning of the quarter for the following quarter. The client has the choice to havethese fees deducted from an account owned by the client other than the managed account, as long as thisagreement is in writing and included with the management agreement on file. If the managed account is heldelsewhere and our Broker Dealer is not the Broker Dealerof record on the account, we will bill for fees quarterlydue within 30 days from billing date.In addition to the asset-based fees, Client assets invested in some mutual fund shares will be subject to other feesand expenses that are described in the individual Fund's prospectuses. These fees and expenses are internally tothe mutual funds return by that mutual fund company and are ultimately borne by the Client as a Fundshareholder. These expenses include investment advisory, administration, distribution, transfer agent, custodial,legal, audit and other customary fees and expenses related to investments in mutual funds, and may includepayments to Leigh Baldwin & Co., LLC and its representatives. This practice may present a conflict of interest andgives Leigh Baldwin & Co., LLC and its supervised persons an incentive to recommend investment products basedon additional compensation received, rather than on the clients’ needs.Pertaining to mutual funds, typically the lowest share cost share class available will be purchased for, or held in,managed accounts in this program. Certain lower cost share classes may be unavailable due to purchaseparameters including but not limited to tax qualification of the account or purchase minimums. A 12b-1 paymentmay be paid to the firm. Accounts that are properly documents as managed accounts will have this 12b-1 paymentrebated to their accounts automatically. Accounts that have not been included in this 12b-1 rebate program willhave their 12b-1 payment that is made to the firm evaluated quarterly for rebate. This will be disclosed to the clientverbally. Clients have the option to purchase these investment products that we recommend through otherbrokers or agents that are not affiliated with Leigh Baldwin & Co., LLC. If A shares are purchased outside of a fee-based platform, the client may be subject to a front-end sales charge which would not be imposed in a managedaccount.Additionally, there may be trade clearing charges assessed on each trade; the clearing firm may assess a fee oneach trade, and additionally the Broker Dealer Leigh Baldwin & Co., LLC would pass this fee plus an operating feethrough to the investment advisor of record. Your investment advisor has discretion if they want to pass any or allof this fee onto the client through either a commission and/or service fee attributable to each trade. There may beadditional trade related fees associated with each trade that may include prospectus fees, regulatory fees,confirmation fees and these may be charged directly to you and disclosed on the trade confirm or charged to thefirm or your IAR directly. Your representative may or may not cover the fees associated with the trading costs. If theIAR does not pay for such costs, you will incur an additional cost each time your IAR recommends the purchase orsale of a security by means of an extra fee charged per trade. This will increase the total costs in your account. Ifyour IAR elects to pay transaction charges, while you will not pay such costs, your IAR is incentivized to either notrecommend transactions, to avoid having to pay such transaction costs, or may recommend investments whichhave lower transaction costs, but which may be more expensive to you. Please refer to Section 12 for additionaldetails on brokerage practices and potential conflicts of interest. There may also be fees associated with transfertaxes, exchange fees mandated by the Securities Exchange Act of 1934, IRA account fees and any other chargesimposed by law regarding on transactions in a clients managed account. Please refer to Item 12 that coversBrokerage Services.Leigh Baldwin & Co., LLC may also receive a portion of other various charges that may be charged in your accountsuch as Margin Interest, Paper Document fee, Annual Custody fee, and TOA delivery fee.Management fees may be prorated for each capital contribution and withdrawal made during the applicablecalendar quarter. Accounts initiated or terminated during a calendar quarter may be charged immediately aprorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and anyearned, unpaid fees will be due and payable. Withdrawals in excess of 10% of the account value will be reviewed forpotential fee credit. ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ITEM 7 TYPES OF CLIENTS ITEM 8 METHOD OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS 10 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comItem 12 further describes the factors that Leigh Baldwin & Co., LLC considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).Leigh Baldwin & Co., LLC does not charge any performance-based fees (fees based on a share of capital gains on orcapital appreciation of the assets of a client).Leigh Baldwin & Co., LLC provides portfolio management services to individuals, high net worth individuals,corporate pension and profit-sharing plans, Taft-Hartley plans, charitable institutions, foundations, endowments,municipalities, and trust programs. We do impose a minimum account size aggregate of $50,000 to be in the LBAManaged Account Program unless otherwise permitted by upper management. For accounts that are referred tooutside SEC registered RIA’s, there is no minimum other than those imposed by those third-party RIA’s and whichis outlined in their own ADV’s. In some cases, we may elect not to take on a client because we do not feel we areest suited to meet their investment needs. Also, we may end a client relationship if we feel we can no longer meettheir investment needs. We try to accommodate a wide range of custodians; however, we may refuse a client whodoes not use a suggested/recommended custodian.Leigh Baldwin & Co., LLC’s investment analysis includes Fundamental and Technical Analysis. FundamentalAnalysis is rooted in mathematical and objective information. Since this type of analysis is heavily based on publiclyavailable information, risks may lay in the quality, publicity and truthfulness of the data provided. TechnicalAnalysis relies on charting patterns in stocks, following volume and price and may result in a short-term purchaserather than a long-term hold due to a change in the charting. Technical trading eliminates external drivers, such asfundamental trading, and focuses on past prices and volume to calculate current and future patterns. By using acombination of these two strategies, the goal of the IAR is to have the discipline to buy fundamentally positivestocks, when the charting works in their favor.We will use a combination of long- and short-term purchases for portfolio management. Most securities arebought with expectations that they will be held for over one year as a long-term purchase, but market conditionsmay warrant a sale sooner than that holding time frame and the securities may be liquidated any time afterpurchase.Dollar Investment Club (DINC) is our branded systematic investment plan identified ultimately as a systematicinvestment plan which combines exchange traded funds, mutual funds and individual equities designed to bepurchased at regular intervals. Leigh Baldwin is the sole investment advisor on these strategies.You can find more information at www.dollarinvestmentclub.com. Though this has been implemented with thetarget to be focused on systematic investing, the strategies and investment policies imposed are also suitable forone-time purchases of varying amounts.Investing in securities involves risk of loss that clients should be prepared to bear.We may use options as part of the investment program, and certain options strategies may bear more risk thanothers. If the investment account warrants a call writing strategy on its portfolio securities it limits its opportunityto profit. If the investment account warrants a purchase of a put option it may lose the entire premium paid for a ITEM 9 DISCIPLINARY INFORMATION ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 11 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comput option. You would expect to generate premiums from a sale of call options. These premiums typically willresult in short-term capital gains for federal income tax purposes. In addition, stocks that are hedged with putoptions may not be eligible for long term capital gains. This investment strategy may not be designed for investorsseeking a tax efficient investment and may or may not be used in your specific account.Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary eventsthat would be material to your evaluation of Leigh Baldwin & Co., LLC or the integrity of Leigh Baldwin & Co., LLC’smanagement. Leigh Baldwin & Co., LLC has as a broker dealer does have disciplinary history, though none of whichwe would deem material to the evaluation of out integrity as an Investment Advisor or would reflect negatively onour Management. For purposes of disclosure, we would like to make you aware of these circumstances so that youcan evaluate for yourself.FINRA alleged that during their review period that we failed to timely report order events (ROES)to the Order AuditTrail Systems (OATS) therefore OATS was unable to link the trades to their reporting system due to inaccurate,incomplete or improperly formatted data.Without admitting or denying the findings, in December of 2010 we signed an Acceptance, Waiver and Consentwith FINRA, and we were fined $10,000, which is the minimum fine that could be imposed for such occurrence. Bytransmitting new reports and subsequent reports, the timestamp occurred prior to the actual receipt of the order,thereby preventing the OATS System from creating an accurate time sequenced record from the receipt of orderto the resolution. Our firm’s supervisory system did not provide for supervision reasonably designed to achievecompliance with applicable laws, regulations and rules relating to OATS Reporting. The transactions in questionwere cleared on a fully disclosed basis through National Financial Services, and through contract, they wereresponsible to report to OATS on our behalf. A system malfunction on their behalf was responsible for theimproperly formatted reports that caused the mismatched time stamp sequence. FINRA’s elucidation is that asthe Broker Dealer we should have had the proper safeguards in place to catch these inconsistencies and fix them.Leigh Baldwin & Co., LLC is dually registered as both a broker-dealer and registered investment advisor. Leigh D.Baldwin is president, owner, and a registered representative of Leigh Baldwin & Co. LLC. Clients are servicedthrough the broker dealer and are sold other investment products that don’t fall under the LBA Managed AccountProgram.Most of our IARs are registered with us as a registered representative, in which they may perform brokerageservices for you and earn revenue from transaction-based commissions. Each IAR is an independent contractorwith LBA. There is a conflict of interest when an IAR is able to choose between offering a client fee-based programsand services (advisory relationship) and/or commission-based products and services (brokerage relationship).There is a difference in how LBA and your IAR are compensated for advisory accounts and brokerage accounts orvariable insurance products. While a client pays a fee to their IAR on an advisory account based on the value ofaccount assets, in their capacities as registered representatives they can offer securities and receive a commission,markup, or markdown or other revenue on each transaction.Leigh Baldwin’s registration as a broker-dealer is material to our advisory business because advisory accounts arecustodied with National Financial Services (unless otherwise requested by the client,) a third-party custodian,where we act in our capacity as an introducing broker-dealer. This results in additional forms of compensation toLBA (see Item 12 – Brokerage Practices).Leigh D. Baldwin is also a small minority owner and investor in another FINRA Broker Dealer, MidwesternSecurities Trading Company, LLC. Leigh’s roles will be relating to business development, a director but not part ofactive management nor does he solicit business on their behalf. ITEM 11 CODE OF ETHICS 12 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comLeigh D. Baldwin is also a licensed insurance agent and may guide clients on what insurance products best suittheir needs, and subsequently sell fixed annuities, life insurance, health insurance and/or long-term care insuranceto these clients.An advisor who would participate in the active managing of client accounts or referring (soliciting) accounts tooutside RIA’s may be registered with our Broker Dealer as a registered representative and also maintain the properlicenses or have received the proper waiver of licenses to act as an IA through our RIA.Our Advisors may engage in activities other than investment advice. This may take their time away from you andpresent certain conflicts that may not be in your best interest, so it is important for you to understand and inquireabout your Advisor’s activities outside of providing you investment advice.We have registered representatives of our FINRA Broker Dealer firm that are owners, principals or dually registeredIA's of their own or a third-party Registered Investment Advisor. We do not participate in the management ofthese RIA’s, though we may share a registered person. The client signs a management agreement with these RIA’sand they are provided with their ADV’s. These accounts may be custodied at National Financial Services with us asBroker Dealer of record on the account. This is not a requirement of our registered representatives, and they arefree to have their IA accounts custodied elsewhere at their discretion.Our investment advisors may refer business to SEC Registered RIA’s. The client signs a management agreementwith the respective RIA’s and they are provided with our ADV as well as their own ADV. Neither the investmentadvisor nor Leigh Baldwin & Co., LLC provides investment advice to clients. Please refer to Item 14 forcompensation arrangements. Leigh Baldwin & Co., LLC may use the research of third-party RIA’s firms over the course of choosing investments inclients’ accounts in the Program. We will pay these firms an agreed upon amount for research services only.We recommend to client’s securities in which the portfolio manager may have some financial interest in. However,orders for clients are required to be placed ahead of Leigh Baldwin & Co.'s related persons. We do recommend toclients or prospective clients the purchase of a security in which employees may have a position or interest.Our Code of Ethics sets forth standards of business conduct required of all employees and independentcontractors. Leigh Baldwin & Co., LLC and it's associated persons will always act in the client’sbest interest and theclient’s interest will always be placed above that of the Company's.This is a summary, and we will provide a copy of our complete Code of Ethics to any client or prospective clientupon request. You may request a copy by contacting Leigh D. Baldwin at 315-655-2964.Leigh Baldwin & Co., LLC has adopted a Code of Ethics for all supervised persons of the firm describing its highstandard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating tothe confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering,restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainmentitems, and personal securities trading procedures, among other things. All supervised persons at Leigh Baldwin &Co., LLC must acknowledge the terms of the Code of Ethics annually, or as amended.Leigh Baldwin & Co., LLC anticipates that, in appropriate circumstances, consistent with clients’ investmentobjectives, it will cause accounts over which Leigh Baldwin & Co., LLC has management authority to effect, and willrecommend to investment advisory clients or prospective clients, the purchase or sale of securities in which LeighBaldwin & Co., LLC, its affiliates and/or clients, directly or indirectly, have a position of interest. Leigh Baldwin & Co.,LLC’s employees and persons associated with Leigh Baldwin & Co., LLC are required to follow Leigh Baldwin & Co.,LLC’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of LeighBaldwin & Co., LLC and its affiliates may trade for their own accounts in securities which are recommended toand/or purchased for Leigh Baldwin & Co., LLC’s clients. The Code of Ethics is designed to assure that the personal  ITEM 12 BROKERAGE PRACTICES 13 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comsecurities transactions, activities, and interests of the employees of Leigh Baldwin & Co., LLC will not interfere with(i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the sametime, allowing employees to invest for their own accounts. Under the Code certain classes of securities have beendesignated as exempt transactions, based upon a determination that these would materially not interfere with thebest interest of Leigh Baldwin & Co., LLC’s clients. In addition, the Code monitors and may restrict trading nearclient trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees toinvest in the same securities as clients, there is a possibility that employees might benefit from market activity by aclient in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, andto reasonably prevent conflicts of interest between Leigh Baldwin & Co., LLC, and its clients.We have no soft dollar arrangements.Leigh Baldwin & Co., LLC is dually registered as a Broker Dealer and a Registered Investment Advisory firm. Byusing our Broker Dealer to execute trades, along with our registered representatives to place these trades, we canmonitor all aspects of best execution including, but not limited to, measuring the pricing on executions,controlling trade errors and eliminating any soft dollar conflicts. We also have unique and wide-ranging clientservicing capabilities to our advantage. With our relationship as both Broker-Dealer and RIA, conflicts of interestcan present themselves. For example, any portion of a ticket fee (commission and service fees) charged would bepaid directly to the representative of record on the account, the broker dealer Leigh Baldwin & Co., LLC or both.This could present a conflict of interest as the representative would be receiving both a management fee andadditional fees that are charged to the trade. The Broker Dealer can and will receive a portion of all trade relatedcharges disclosed on the trade confirm that are above our cost to the clearing firm to clear the trade. See Item 5pertaining to Fees and Compensation.National Financial Services (NFS) is the clearing firm for LBC’s brokerage business and is a custodial option for itsadvisory accounts. As part of this business relationship, LBA pays NFS various execution and clearing charges andfees in connection with NFS maintaining custody of LBC’s clients’ accounts. NFS’s execution and clearing chargesare included in the commissions, transaction charges and service fees or other fees that LBA charges its clients.NFS pays LBA the portion of commissions and transactions fees that exceed its execution and clearing charges.LBA may share this revenue received from NFS for investment advisory accounts with our IARs or maintain thatrevenue for the firm.NFS charges Leigh Baldwin & Co., LLC for certain services for your account to be custodied with them, includingbut not limited to clearing transactions, outgoing transfers, wiring of funds, paper statements and confirms,margin extensions, margin interest, ticket charges, asset-based fees, and IRA custodial maintenance andtermination of accounts. LBA has the discretion to set its own charge for its services, which are designed to coverits costs of doing business (including overhead and other costs) as well as provide a profit to LBA charges clientsmore for certain services than it pays NFS, which is sometimes called a “markup,” and the markups vary by productand the type of service, and LBA keeps the difference of this charge. This practice creates a conflict of interest forus since we have a financial incentive to recommend NFS since we receive economic benefit for the services weprovide.The Firm has discretion to recommend or select custodians and custodial platforms for client accounts. In additionto National Financial Services LLC, the Firm makes Altruist available as a qualified custodian for certain managedaccounts. The Firm seeks best execution by considering a range of factors, including execution capability, range ofservices, responsiveness, and overall cost to clients. The Firm’s custodial arrangements are reviewed periodically toassess execution quality, service levels, and overall client impact.Leigh Baldwin & Co., LLC maintains an institutional relationship with Altruist whereby Altruist provides certainbenefits to the firm, including a fully digital account opening process, a variety of available investments, andintegration with software tools that can benefit the firm and its clients. Leigh Baldwin Advisory is not affiliated withAltruist. Altruist does not supervise The Firm’s Advisors, its agents, activities, or its regulatory compliance. ITEM 13 REVIEW OF ACCOUNTS ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION 14 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comCertain accounts custodied at Altruist may be eligible for participation in the Altruist One platform, which providesenhanced features such as tax‐aware portfolio management tools and enhanced cash management options. TheFirm’s decision to offer the Altruist One platform creates a conflict of interest because the platform results in anadditional cost to the Firm and the Firm has discretion in determining which client accounts are eligible for orplaced on the platform. Although clients do not pay an additional advisory fee for participation in the Altruist Oneplatform, the Firm incurs a platform fee of approximately 0.12% of assets under management when accounts areplaced on the platform. As a result, the Firm’s recommendation or selection of custodial platforms could beinfluenced by factors other than the client’s advisory fee. The Firm addresses this conflict by evaluating platformeligibility based on objective, client‐specific factors, including account type, tax status, cash balances, and whetherthe platform’s features are reasonably expected to provide a meaningful benefit to the client. Not all client accounts will be eligible for or placed on the Altruist One platform. Accounts that consist primarily ofqualified assets or that maintain minimal cash balances may not receive meaningful benefit from the platform’stax‐aware or cash management features and therefore may not be placed on the platform. The Firm does notreceive any additional compensation, revenue sharing, or other financial incentives from Altruist as a result ofplacing client accounts on the Altruist One platform.There may be a material conflict of interest when a brokerage account converts to an advisory account, which istaking a transaction-based commission relationship to an asset-based fee relationship. The IAR has a duty to fullydetermine whether the transition to one relationship considers costs but also weighs the uniquely different levelsof service. In an advisory relationship these can include a fiduciary role, financial planning and software availability,discretionary versus self-directed, and levels of service. LBA has policies and procedures to review all investmentrelationship types, and these are approved based on the alternatives available at a given time.LBA is both a registered SEC RIA and Broker-Dealer with access to many types of investment programs. Our IAR’shave several choices of platforms to best meet the needs of their clients. We have multiple clearing agreements,and our reps can use other third-party clearing firms, based on both firms’ approvals. Within current platforms, anIAR can choose to use our traditional LBA managed accounts, tiered fee accounts with access to other managers,or a combination of the two. They can also perform financial planning for a fee only. A conflict of interest couldarise when an IAR does not offer the platform that best suits the goals and requirements of the client. In order tomitigate this potential conflict, we are consistently educating our IAR’s and reviewing client accounts with respectto costs, service and goal attainment.Managed accounts are generally reviewed at least quarterly, based upon account positions and activity. Inaddition, client positions (individual securities, ETFs, Mutual Funds, etc.) are analyzed regularly to mitigate the riskin a portfolio and to determine the potential growth or income of the position. We utilize internal and externalresearch to analyze positions with our core investment philosophy in mind that earnings and profits are theultimate driver of total returns and future growth. If a client has a question, request, deposits or withdrawals funds,a relevant review of his or her portfolio is triggered. All portfolios are reviewed by Leigh D. Baldwin or StefanieDorozynski or a designated principal within the firm.At the very least quarterly statements are sent from the brokerage firm to clients. Leigh Baldwin & Co., LLC doesnot prepare these reports. We may send clients an additional report of performance quarterly. Please refer to Item15 concerning custody of client accounts.Pursuant to a written referral agreement between Leigh Baldwin & Co., LLC and unaffiliated broker-dealers,investment advisors and other parties or affiliated investment advisors of Leigh Baldwin & Co., LLC (collectively,“Solicitors”), Solicitors agree to refer prospective clients to us to participate in our investment managementprograms. Leigh Baldwin & Co., LLC, under the written referral agreement between Solicitor and/or Advisor, pays ITEM 15 CUSTODY ITEM 16 INVESTMENT DISCRETION 15 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comSolicitor an annual fee for each client accepted by us for participation in our programs. This fee varies by client andis disclosed to the client on the LBCM Program Account Agreement, which is presented at the time a client entersinto the Management Agreement with Leigh Baldwin & Co., LLC. This fee compensates Solicitor for referringclients to us, assisting in the enrollment of clients for participation in our programs, and facilitatingcommunication between us and clients. The total advisory fee charged to the client by Leigh Baldwin & Co., LLC (asset forth in Item 5) will include the referral fee and does not increase as a result of a referral arrangement. Theclient would not be charged any lesser of an advisory fee if there was not a referral agreement in place.Leigh Baldwin & Co., LLC may be compensated as a solicitor from outside Registered RIA’s previously discussed inItem 10. These RIA’s will compensate our registered representatives with a certain percentage of the total feecharged to the client. This amount is agreed upon in the Solicitors Agreement signed by the registeredrepresentative and the outside RIA as listed previously. This income generated from the management fees is paidout to each registered representative at their respective payout. The amount remitted in solicitor’s fee will vary byaccount agreement. It will typically range annually anywhere from .20% to 2.00% based on allowable assets undermanagement for the billing period. This amount is based on the respective RIA’s fee schedule.Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian thatholds and maintains client’s investment assets. Leigh Baldwin & Co., LLC urges you to carefully review suchstatements and compare such official custodial records to the account statements that we may provide to you.Our statements may vary from custodial statements based on accounting procedures, reporting dates, orvaluation methodologies of certain securities.Our custody is deemed solely for the purposes to deduct advisory fees and does not imply in any way that LeighBaldwin & Co., LLC has custody of client securities or any more authority than that for trading authority or theauthority to deduct fees for the purposes of an investment advisory fee.Client assets are maintained at qualified custodians, including National Financial Services LLC and AltruistFinancial LLC.Leigh Baldwin & Co., LLC would receive discretionary authority from the client at the outset of an advisoryrelationship to select the identity and quantity of securities to be bought or sold. In all cases, however, suchdiscretion is to be exercised in a manner consistent with the stated investment objectives for the client account.Investment discretionary authority is granted to Leigh Baldwin & Co., LLC initially upon signing the managementagreement, and is effective from the date of the agreement to the date in which either party terminates thatagreement.When selecting securities and determining the investment, Leigh Baldwin & Co., LLC observes the investmentpolicies, limitations and restrictions of the clients for which it advises. For registered investment companies, LeighBaldwin & Co., LLC’s authority to trade securities may also be limited by certain federal securities and tax laws thatrequire diversification of investments and favor the holding of investments once made.Investment guidelines and restrictions must be provided to Leigh Baldwin& Co., LLC. Leigh Baldwin& Co., LLCreserves the right to refuse the account based on restrictions implied as they may hamper the intent of theprogram and its investment decisions as covered in Item 4. ITEM 17 VOTING CLIENT SECURITIES ITEM 18 FINANCIAL INFORMATION 16 Leigh Baldwin & Co., LLC112 Albany Street, Cazenovia, NY 130351 (800) 659-8044 | www.leighbaldwinadvisory.comAs a matter of firm policy and practice, Leigh Baldwin & Co., LLC does not have any authority to and does not voteproxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and allsecurities maintained in client portfolios. Leigh Baldwin & Co., LLC may provide advice to clients regarding theclients’ voting of proxies.Registered investment advisors are required in this Item to provide you with certain financial information ordisclosures about Leigh Baldwin & Co., LLC’s financial condition. Leigh Baldwin & Co., LLC has no financialcommitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not beenthe subject of a bankruptcy proceeding. For more information contact: Leigh Baldwin & Co., LLC 112 Albany Street Cazenovia, NY 13035 1 (800) 659-8044 www.leighbaldwinadvisory.com www.leighbaldwinadvisory.com You do the dreaming,we’ll do the math.© Copyright 2025.Advisory services offer through Leigh Baldwin & Co., LLC.LEIGH BALDWINADVISORY