Sentinel Pension Advisors, Llc.

Sentinel Pension Advisors, LLC. 100 Quannapowitt Parkway Wakefield, MA 01880 Phone: 781.914.1361 Fax: 781.213.6742 Website: www.sentinelgroup.com FORM ADV PART 2A Firm Brochure This brochure provides information about the qualifications and business practices of Sentinel Pension Advisors, LLC. If you have any questions about the contents of this brochure, please contact SPA at 781-914-1361.The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Sentinel Pension Advisors, LLC. also is available on the SEC website at www.adviserinfo.sec.gov.The searchable IARD/CRD number for Sentinel Pension Advisors, LLC. is 109901. Sentinel Pension Advisors, LLC. is a Registered Investment Advisor. Registration with the SEC or any other state securities authority does not imply a certain level of skill or training. March 31, 2026  II. MATERIAL CHANGES Annual Update This brochure is filed as the annual amendment for the form ADV Part 2. The annual update was March 31, 2026.The Material Changes section of this brochure will be updated annually, and when material changes occur since the previous release of the Firm Brochure. Material Changes Since the Update in 2025 There have not been any material changes since the last update. FORM ADV PART 2A FIRM BROCHURE 2  Brochure Availability Sentinel Pension Advisors, LLC. (“SPA”) offers or delivers information about our qualifications and business practices to clients on at least an annual basis. SPA will ensure that you receive a summary of any material changes to this and subsequent brochures within 120 days of the close of the business’ fiscal year. SPA may further provide other ongoing disclosure information about material changes as necessary. Sentinel Pension Advisors, LLC. will further provide you with a new brochure as necessary based on changes or new information, at any time, without charge. Currently, this brochure may be requested by contacting Sentinel Pension Advisors, LLC. at 781-914-1361. This brochure is also available on Sentinel Pension Advisors, LLC.’s website, www.sentinelgroup.com, free of charge. Additional information about Sentinel Pension Advisors, LLC. is also available via the SEC’s website www.adviserinfo.sec.gov.The SEC’s website also provides information about any persons affiliated with Sentinel Pension Advisors, LLC. who are registered, or are required to be registered, as investment advisor representatives of Sentinel Pension Advisors, LLC. Sentinel Pension Advisors, LLC. will further provide you with a new brochure as necessary based on changes or new information, at any time, without charge. FORM ADV PART 2A FIRM BROCHURE 3  III. TABLE OF CONTENTS II. MATERIAL CHANGES .................................................................................................. 2 III. TABLE OF CONTENTS ................................................................................................ 4 IV. INVESTMENT ADVISORY BUSINESS. ......................................................................... 5 V. FEES AND COMPENSATION. ................................................................................... 12 VI. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...................... 17 VII. TYPES OF CLIENTS. .................................................................................................. 17 VIII. METHOD OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS. ......... 17 IX. DISCIPLINARY INFORMATION. ............................................................................... 22 X. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS. .......................... 22 XI. CODE OF ETHICS, PARTICIPATION or INTEREST IN CLIENT TRANSACTIONS, and PERSONAL TRADING. ............................................................. 27 XII. BROKERAGE PRACTICES. ....................................................................................... 29 XIII. REVIEW OF ACCOUNTS. ..................................................................................... 30 XIV. CLIENT REFERRALS AND OTHER COMPENSATION. ......................................... 31 XV. CUSTODY ............................................................................................................... 33 XVI. INVESTMENT DISCRETION. ................................................................................. 34 XVII. VOTING CLIENT SECURITIES. .............................................................................. 34 XVIII. FINANCIAL INFORMATION. ............................................................................... 34 XIX. REQUIREMENTS FOR STATE REGISTERED ADVISERS. ........................................ 35 FORM ADV PART 2A FIRM BROCHURE 4  IV. INVESTMENT ADVISORY BUSINESS Sentinel Pension Advisors, LLC.“SPA” was established in July 1998 and is an SEC Registered Investment Advisor with its principal place of business in Wakefield, Massachusetts. SPA is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, SPA is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because SPA is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of SPA. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. We offer clients the option of obtaining certain financial solutions from unaffiliated third- party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. As of December 31, 2025, SPA’s discretionary assets under management were $2,978,308,165 in 2,587 accounts. Non-discretionary assets under management were $8,963,622,969 in 446 accounts.The total assets under management were $11,941,931,134 in 3,033 accounts. SPA provides investment advisory services to institutional clients such as corporate, trust, estate and retirement accounts, as well as pension and profit sharing plans. SPA also offers advisory services to individual investors including individual portfolio advisory services, third party separately managed accounts (“SMA’s”), managed account services “The SPA Wrap Fee Program”, and retirement plan advisory services.The SPA Investment Committee manages all individual investment models as well as the SPA Wrap Fee Program based on the stated objectives of the model or program guidelines. Individual Advisory Representatives manage individual portfolios based on the client’s individual needs and objectives.. SPA receives a portion of the advisory or management fee for services rendered. SPA is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including plan participants. SPA is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, SPA is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited FORM ADV PART 2A FIRM BROCHURE 5  transaction exemption. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Education & Business Standards SPA requires those involved in determining or providing investment advice to clients to meet certain general standards of educational and business experience. With respect to persons who are involved in SPA’s provision of advice, SPA requires all such individuals to have a college degree in an applicable area and/or equivalent industry experience. In addition, SPA requires successful completion of any applicable examinations. SPA also encourages its personnel to obtain applicable professional designations. SPA has an investment committee comprised of SPA portfolio managers, management, and employees of SPA.The investment committee meets on at least a quarterly basis to discuss, in general terms, SPA’s risk management, asset allocation, investment strategy, and performance.The investment committee may also invite others to serve as advisors or consultants to the committee. SPA Investment Advisory Services A. Individual Investors Individual Advisory Services SPA provides Investment Supervisory and Advisory Services, defined as giving continuous advice to a client or making investments for a client based on the individual needs of the client. Prior to opening an account, SPA determines an investor’s profile by obtaining the appropriate financial and personal information from the investor including investment objectives, risk tolerance, and investment time horizon, as well as any restrictions (as agreed upon between SPA and the client) that the client wishes to impose upon the management of the portfolio. Through the data gathered on an investor’s profile and personal discussions in which goals and objectives based on a client’s particular circumstances are established, SPA develops a detailed investment plan and recommends an initial asset allocation best suited to achieve both portfolio and investment objectives.Typically, under this style of management, SPA will allocate the client’s assets among a portfolio of various mutual funds and exchange-traded funds (“ETFs”) taking into consideration the overall management style the client selects.The majority of investment vehicles are mutual funds, however some clients have the ability to self-direct investments in their retirement plans.They may also choose other investment vehicles in their brokerage accounts.The individual funds and ETFs will be primarily selected by SPA on the basis of each fund’s performance history and investment objectives. Clients will have the opportunity (as agreed upon between SPA and the client) to restrict the types of investments which may be made on the client’s behalf. An investment advisor can assist clients in their decision to implement the investment plan that most closely matches their investment objectives and strategy. Adjustments will be made to client portfolios periodically based on market conditions, client instructions or changes in client objectives. SPA will manage advisory accounts FORM ADV PART 2A FIRM BROCHURE 6  on either a discretionary or non-discretionary basis. Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, income, or growth and income). To help SPA provide accurate and timely management of your invested assets, SPA requires clients to establish an account with a designated “qualified custodian”, as that term is defined in Rule 206(4)-2(d)(6) of the Investment Advisers Act of 1940. The custodian of the client’s funds and securities is generally Pershing, LLC (Member NYSE/FINRA/SIPC) (“Pershing”), Fidelity Investments Brokerage, LLC (Member NYSE/ FINRA/SIPC (“Fidelity Investments”), or Charles Schwab & Co., Inc. (Member NYSE/ FINRA/SIPC) (“Schwab”). The custodian maintains the underlying records for the assets held in client accounts. SPA will not serve as the custodian for client advisory assets. Clients are solely responsible for paying all the fees and charges of the custodian, as stated in your agreement with the custodian. Recommendation of External Managers For certain clients, SPA recommends the allocation of their assets to External Managers to provide discretionary investment management services. In such cases, SPA conducts due diligence and monitoring of the External Managers, helps to facilitate the engagement of the External Manager and communicates with clients regarding their investment with the External Manager and charges its investment advisory fee for these services.The External Managers charge fees that are separate from and in addition to SPA’s advisory fee. Managed Account Services “The SPA Wrap Fee Program” The SPA Wrap Fee Program (the “Program”) is a fee-based program sponsored by SPA. Under the Program, SPA assists clients to develop, monitor, and manage a custom-tailored investment portfolio to help achieve the client’s investment objectives. The client grants discretionary authority over the client’s assets to SPA to buy, sell and trade investment vehicles which may include no-load and select load- waived mutual funds, ETFs and other securities approved for the Program (including stocks, bonds and options) and to liquidate previously purchased load mutual funds, stocks, bonds, options, ETFs and other investments; except for the fees related to the Program itself, clients pay no transaction fees or commissions.Thus, an account with more frequent trades, will, generally, pay less overall fees, than in an account type that would charge transaction fees and commissions to clients. Conversely, an account with less frequent trading may incur higher fees in this Program, than if it were invested in another program. As more fully described below in “Methods of Analysis, Investment Strategies and Risk of Loss,” SPA follows a disciplined research and evaluation process to determine appropriate investments for each model portfolio based on its target allocation. Along with this disciplined approach to managing client portfolios, SPA has the expertise and analytical tools to choose from thousands of funds and fund families with a wide range of investment managers.This provides SPA with the flexibility to analyze leading investments in each asset class and develop risk based portfolios designed to develop investment strategies used by the model portfolios offered by the Program. Each portfolio is created with SPA’s in depth analysis and screening criteria.There are currently nine model portfolios - Moderate, Moderate Plus, Balanced, Growth, Moderate ESG, Balanced ESG, Growth ESG, Municipal Income, and Qualified Income FORM ADV PART 2A FIRM BROCHURE 7  - so clients can select the portfolio that will work best for their investment goals. An investment advisor can assist clients in their decision regarding which portfolio most closely matches their investment strategy. SPA requires an account minimum of $25,000 for participation in the Program. However, SPA, in its sole discretion, may reduce the account minimum based upon certain criteria including, among others, anticipated future additional assets, dollar amount of assets to be managed, related accounts and account composition. The custodian of the client’s funds and securities under the Program (the “Custodian”) is generally Pershing, LLC (Member NYSE/FINRA/SIPC) (“Pershing”). By participating in the Program, each client instructs SPA to direct all orders for the purchase and sale of securities and other investments for the client’s account to Sentinel Securities, LLC, an SEC-registered broker-dealer (Member FINRA/SIPC) (“Sentinel Securities”) and SPA affiliate, as introducing broker for the client’s account. Sentinel Securities maintains a clearing arrangement with Pershing, LLC, a division of Bank of New York (“Pershing”) whereby Sentinel Securities clears securities transactions on a fully disclosed basis through Pershing as an introducing broker, and Pershing holds customer funds and/or securities on behalf of Sentinel Securities, LLC brokerage customers for purposes of the Securities Investor Protection Act. Financial Planning Services FINANCIAL PLANNING AND FINANCIAL CONSULTING SPA offers various types and levels of financial planning and consulting services. The level and type of services will vary among the Advisory Representatives and will depend on the needs of the client. Services may include, but not be limited to, the following examples of services. Insurance Needs Analysis • Retirement Planning • General, Segmented and Comprehensive Financial Planning • Educational Planning • Cash Flow Analysis • Estate Planning • Budget Planning • Tax Planning • • Business Continuity, Succession and Exit Planning • Asset Allocation Services • Executive Planning • Corporate Benefit Consulting • Other planning and consulting services as requested by the client and agreed to by the Advisory Representative SPA will gather financial information and history from clients, which may include, among other things, retirement and financial goals, investment objectives, investment horizon, financial needs, cash flow analysis, cost of living needs, education needs, savings tendencies, and other applicable financial information required by SPA in order to provide the investment advisory services requested. As stated above, the level and type of services will depend on the needs of the client. Depending on the services requested, clients may receive a written analysis, summary or plan. One or more meetings may be necessary with the client and may involve other professionals, as invited and FORM ADV PART 2A FIRM BROCHURE 8  agreed to by the client, such as attorneys and/or certified public accountants. Planning and consultative services are based on the client’s financial situation at the time and on financial information disclosed by the client to SPA. Clients are advised that plans may contain certain assumptions that may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. SPA cannot offer any guarantees or promises that clients’ financial goals and objectives will be met. Further, clients must continue to review any plan or analysis and update the plan based upon changes in the client’s financial situation, goals, or objectives or changes in the economy. Should a clients’ financial situation or investment goals or objectives change, clients must notify SPA promptly of the changes. Clients are advised that fees for planning and/or consultative services are strictly for the planning services.Therefore, clients may pay fees and/or commissions for additional services obtained, such as asset management or products purchased, such as securities or insurance. GENERAL DISCLOSURES A conflict of interest may exist between the interests of SPA and/or its Advisory Representatives and the interests of the client. SPA and Advisory Representatives offer financial planning and investment advisory services for a fee and also offer various securities products for which they may be paid a commission.The SPA Code of Ethics requires SPA Advisory Representatives to put their clients’ interests first, and the SPA Compliance Department monitors for inappropriate account activity. If an Advisory Representative is found to have received commissions where the client should have had the transaction placed in the client’s advisory account, SPA will take action to correct the situation, including reversing the transaction and the commission and possible sanctions against the Advisory Representative. Further, the securities products available through SPA may be limited to certain products that have been reviewed and made available for offering through the broker dealer with which Advisory Representatives may be registered representatives. Lower fees for comparable services may be available from other sources. Material conflicts of interest disclosed to the client in writing via this Form ADV Part 2 could cause SPA or its Advisory Representatives to not render unbiased and objective advice. The level of experience of Advisory Representatives will vary. Additionally, the fees charged by various Advisory Representatives will not exceed the fee schedules disclosed herein but may vary.Therefore, clients receiving similar services may pay higher or lower fees than another client depending on their Advisory Representative. A higher fee is not necessarily commensurate with the experience of the Advisory Representative. As a standard practice, SPA does not take action or provide advice to clients on legal proceedings, such as bankruptcies or class actions, related to securities held (currently or previously) in client accounts. Clients are encouraged to contact their custodian with any such matters. A. Retirement Plan Sponsors and Investment Advisors SPA provides investment advisory consultant services and retirement plan investment management to advisors, clients, for itself and on behalf of the plan and plan participants. Investment Advisory Consulting Services FORM ADV PART 2A FIRM BROCHURE 9  SPA provides services to assist plan sponsors, plan trustees, investment committees and financial advisors to meet ERISA fiduciary responsibilities under 404(c).These consulting services range from the development of Investment Policy Statements to the delivery of Participant Communication services. Investment Policy Statement – SPA will develop a Statement of Investment Policy for your retirement plan that provides the guidelines for selecting and evaluating investments offered in your plan. SPA will work with the firm to create an Investment Policy Statement consistent with ERISA.The Policy will document the plan’s objectives and set into writing the plan’s investment policies regarding investment selection, monitoring, benchmarking, and de-selection. Manager Selection – SPA’s investment manager research and selection process is a fully integrated process designed to select asset managers for each asset class and style to be represented within the plan. Our quantitative screening assesses whether each manager meets standards for style consistency, risk adjusted performance, consistency of performance and low expenses. Our experienced analysts further assess the philosophy behind the numbers, the process by which it is implemented and most importantly— the people who manage the portfolios. Monitor & Measure – SPA will establish and manage a process to select, de-select, and monitor investments offered to plan participants. SPA will evaluate the plan’s current offering by benchmarking the investment return, risk, and expenses to its peers and relative indices, by providing an assessment of asset class overlap or gaps, and by evaluating overall investment offering to the plan’s current investment policy statement. Trustee & Investment Committee Meetings – SPA meets regularly with the Plan Trustees & Investment Committees to document the performance of the plan’s investments and to make any recommendations that may be appropriate for changes. These meetings are documented and become part of the plan’s due diligence file. Lifestyle Portfolio Management – SPA will develop and manage portfolios designed to meet specific risk and return characteristics.These models will be comprised mainly of investments offered to plan participants. SPA may also serve as the advisor on these lifestyle portfolios in an advisory or sub-advisory arrangement under ERISA § 3(21) and ERISA § 3(38). (Detailed in the Retirement Plan Investment Management Services section below.) Participant Communication – SPA will provide group meetings and individual participant meetings to help participants achieve better financial results.The schedule, timing and number of meetings shall be determined prior to contract acceptance. Retirement Plan Investment Management Services SPA provides services to assist plan sponsors, plan trustees and investment committees to meet their ERISA fiduciary responsibilities. SPA provides these services under ERISA § 3(21) and ERISA § 3(38). Under these sections, clients can engage SPA to provide investment advisory services. By doing so, SPA shares fiduciary responsibility with plan trustees and investment committees as it relates to the assets SPA is under agreement to provide investment management or advisory services. As a part of a client’s fiduciary team, SPA provides the investment expertise to implement the plans investment policies and objectives. SPA acting as an advisor under ERISA § 3(21) For the purposes of ERISA § 3(21), SPA does not exercise any discretionary authority or FORM ADV PART 2A FIRM BROCHURE 10  control with respect to management of the plan or management or disposition of its assets or have any discretionary authority or discretionary responsibility in the administration of the plan.Therefore, SPA is not a “fiduciary” pursuant to ERISA except to the extent it renders “investment advice” to the plan within the meaning of section 3(21) of ERISA and Department of Labor regulations there under.The participants are responsible for any individual investment selections made under the plan. Under ERISA § 3(21), SPA acts as the advisor making investment recommendations, but it is ultimately up to the plan sponsor to decide whether and how to implement these recommendations. Furthermore, under ERISA § 3(21), the participants are responsible for any individual investment selections made under the plan. SPA acting as an investment manager under ERISA § 3(38) For the purposes of ERISA § 3(38), SPA serves as the investment manager, who exercises discretionary authority with regard to the model portfolios it develops and with regard to the mutual funds and other investment vehicles that it selects for investment under the Plan.Therefore, SPA is not a “fiduciary” pursuant to ERISA except to the extent it renders “investment advice” to the plan within the meaning of section 3(38) of ERISA and Department of Labor regulations there under.The participants are responsible for any individual investment selections made under the plan. Under ERISA § 3(38), SPA acts as the advisor with discretionary authority with regard to the investments managed for the plan, allowing the plan sponsor to transfer liability for selecting‚ monitoring‚ and replacing the investment options to SPA, the investment manager. Furthermore, under ERISA §3(38), the participants are responsible for any individual investment selections made under the plan. C. Termination of SPA Investment Advisory Services Individual Investment Advisory Agreements I. INVESTMENT MANAGEMENT AGREEMENT Clients may terminate the Investment Management Agreement without penalty within 5 business days after the execution of the Agreement. Subsequently, either the client or SPA may terminate this Agreement at any time upon written notice to the other party. If termination occurs prior to the end of a calendar billing period, a pro- rata refund of unearned fees will be made to the client. In the event of termination of the Agreement, SPA shall have no obligations whatsoever to recommend any action with respect to or to liquidate the assets in the Account. SPA shall be entitled to be paid its fees in connection with its services provided hereunder for the period to such termination. II. WRAP-FEE PROGRAM CLIENT AGREEMENT Either the client or SPA may terminate the Client Agreement effective as of the end of a quarter upon advance written notice to the other prior to the end of such quarter. In the event of termination of the Client Agreement, SPA shall have no obligations whatsoever to recommend any action with respect to or to liquidate the assets in the client’s account. SPA shall be entitled to be paid its fees in connection with its services provided under the Client Agreement for the period to such effective termination.Thus, SPA may withhold a pro-rata portion of the pre-paid advisory fees for bona fide advisory services actually rendered during the quarter prior to such effective termination. Notwithstanding the foregoing, pursuant to applicable laws, SPA FORM ADV PART 2A FIRM BROCHURE 11  will refund excess advance payment to the extent that bona fide services have not been provided during such period. In addition, each client is required to notify SPA in the event that the client intends to withdraw assets in the client’s Program account to a level below the account minimum. Upon termination of any account, any prepaid unearned fees will be refunded based upon the number of days remaining in the quarter after the termination date, and any earned unpaid fees will be due and payable. Consulting and Retirement Plan Advisory Services Agreements I. INVESTMENT ADVISORY CONSULTING SERVICES II. INVESTMENT ADVISORY 3(21) AGREEMENT III. INVESTMENT ADVISORY 3(38) AGREEMENT An Investment Consulting Services or Retirement Plan Advisory agreement may be terminated without penalty by either party providing sixty (60) days advance written notice to the other party. However, any fees due to SPA for services provided prior to date of termination will be payable upon receipt of invoice. Upon termination of an Agreement, SPA will have no obligation to recommend or take any action with regard to the securities, cash or other investments in the Account, but will cooperate with the plan sponsor to facilitate the orderly transition of the Account(s). V. FEES AND COMPENSATION All fees are subject to negotiation.Some factors considered are the size of the account and the type of assets managed.The specific manner in which fees are charged by SPA varies by the Advisory program chosen. The advisory fees paid to SPA represent fees for management of your account and are separate from any other fees and expenses charged by other parties; therefore, the advisory fees shown in this ADV represent only the fees paid to SPA and do not reflect operating expenses and other costs charged by the mutual funds, or other products you may be invested in and it is important you understand that these expenses and costs are ultimately borne by you, as the shareholder. In addition, mutual funds may charge contingent deferred sales charges (“CDSC”) on withdrawals. SPA is not responsible for any CDSC charges incurred through SPA’s management of your portfolio or for any transaction costs incurred while managing your assets. A complete description of all fees and expenses of the securities in which you are invested are contained in the relevant prospectuses. SPA also advises you to carefully review your custody agreement with your custodian as there may be custodial fees and other service fees charged to you by your custodian. SPA reserves the right to waive the advisory fee for certain accounts and assets. The standard fee schedules and minimum account sizes indicated for the investment management services identified below are negotiable and as a result clients with similar assets have differing fee schedules and pay different fees. If an account is terminated prior to the end of a calendar billing period, a pro-rata refund of unearned fees will be made to the client. Many investment management client relationships predated the implementation of SPA’s current fee schedule. For this reason, clients’ fees may be higher or lower than those reflected in the foregoing schedule or be subject to additional or differing terms. Moreover, SPA clients originating from firms who merged into SPA will have fee schedules different than SPA’s standard fee schedule. FORM ADV PART 2A FIRM BROCHURE 12  The same or similar investment advisory services may be available from other investment advisors for a lower fee.The advisory fee may be more or less costly than paying for the services separately, depending upon the investment advisory fees charged, the number of transactions for the account, the level of brokerage, and other fees that would be payable if the client obtained the services available under the program individually. Sentinel has waived or reduced the asset- based management fee for some of its employees and their family and friends of the firm. SPA’s investment advisory services and associated fees are as follows: A. Individual Advisory Services, Managed Account Services “The SPA Wrap Fee Program” I. INDIVIDUAL ADVISORY SERVICES PROGRAM The Advisory Services fee is based on a percentage of the Client’s total assets under management with SPA.The Program fee is calculated and charged on a quarterly basis in advance (although in some cases, the Program fee may be calculated and charged in arrears instead). Asset Value (Annualized) $25,000 to $249,999 From $250,000 to $499,999 From $500,000 to $999,999 Annual Fee* 1.50% 1.25% 1.00% 0.85% 0.60% From $1,000,000 to $4,999,999 From $5,000,000 *Specified rate applies only to assets in this tier. All fees are negotiable subject to the specifics of each client and situation. Clients who engaged SPA prior to January 1, 2024 may be subject to fee schedules that use a blended fee rate rather than the tiered fee rate shown above. Clients must pay the fees in advance.The applicable Advisory Fees referenced above include fees and charges for the services of SPA and advisory representatives.The fees do not include transaction costs charged by the custodian, brokerage charges, IRA and Qualified Retirement Plan annual account and termination fees which are set forth in the client agreement between Sentinel Securities, LLC, Fidelity Brokerage, LLC, or Charles Schwab & Co., Inc. and the client. Fees for SPA’s investment management services are separate from and in addition to any transaction or similar/fees expenses charged by Separately Managed Accounts (“SMAs”). For SMAs, SPA generally deducts its advisory fee from such accounts. Each SMA generally deducts its management fee pursuant to its agreement and arrangement with the client. For traditional asset classes, the additional fee paid to an External Manager generally ranges from a minimum of .15% to a maximum of .70%. SPA does not receive, directly or indirectly, compensation from independent managers that it recommends or selects for its clients. In general, the first payment is due upon execution of the SPA Investment Advisory Agreement and will be assessed pro-rata in the event the agreement is executed at any time other than the first day of the calendar quarter. Subsequent payments are due and will be assessed on the first day of each quarter based upon the value of assets under management as of the close of business on the last business day of the preceding quarter as valued by an independent pricing service, where available, or otherwise in good faith. Pursuant to applicable laws, SPA will refund excess advance payments to the extent that bona fide services have not been provided during such period. FORM ADV PART 2A FIRM BROCHURE 13  II. MANAGED ACCOUNT SERVICES “THE SPA WRAP FEE PROGRAM” Clients pay a single asset based fee within the SPA Wrap Fee Program.The SPA Wrap Fee Program fee will be set forth in the Client Agreement and is based on a percentage of the client’s total account assets under management in the Program.The Program fee is calculated and charged on a quarterly basis in advance (although in some cases, the Program fee may be calculated and charged in arrears instead). Generally, client’s must pay the fees in advance. Asset Value (Annualized) $25,000 to $249,999 From $250,000 to $499,999 From $500,000 to $999,999 From $1,000,000 to $4,999,999 From $5,000,000 Annual Fee* 1.50% 1.25% 1.00% 0.85% 0.60% *Specified rate applies only to assets in this tier. All fees are negotiable subject to the specifics of each client and situation. Clients who engaged SPA prior to January 1, 2024 may be subject to fee schedules that use a blendedfee rate rather than the tiered fee rate shown above. SPA may, in its sole discretion, negotiate the Program fee paid by the client depending on considerations, including, but not limited to, the size of the client’s account, the amount of time that the client has had an account or accounts with SPA and/or Sentinel Securities, LLC, the total amount of business that the client conducts through SPA and/or Sentinel Securities, LLC, the types of investments and services provided, anticipated future additional assets and other relevant criteria. Under the Program, an investor receives both investment advisory services and the execution, clearing and settlement of securities brokerage transactions for a single specified fee. Pershing, LLC and Envestnet provide Program Clients with quarterly billing under its automated billing system at no additional fee to Program Clients.An investor’s participation in the Program may cost the investor more or less than purchasing such advisory, brokerage and other services separately. In addition, the Program fee may be higher or lower than that charged by sponsors of other comparable wrap fee programs. Pursuant to applicable laws, SPA will refund excess advance payments to the extent that bona fide services have not been provided during such period. A portion of the fees paid to SPA are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. Some custodians have introduced programs that eliminate transaction-based fees for trades of equities and exchange-traded funds (ETF’s). For equities and ETFs that are no longer subject to these transaction fees, SPA is no longer paying those transaction costs on behalf of clients and thereby benefits from a reduction in expenses associated with its wrap programAlthough this change does not impose any new costs on clients, it does reduce the economic benefit of participating in a wrap program. The client may be responsible for paying certain charges in addition to the Program fees. Such charges include, but are not limited to, charges imposed directly by a mutual fund purchased for the client’s account, which shall be disclosed in the mutual fund’s prospectus (e.g. fund management fees and other fund expenses), certain deferred sales charges on previously purchased mutual funds, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, charges by the Custodian to deliver statements and reports in paper format, postage and overnight shipping, IRA account maintenance fees and other fees on securities transactions mandated by law. SPA does not receive, directly FORM ADV PART 2A FIRM BROCHURE 14  or indirectly any of these fees charged to you.They are paid to your broker, custodian or the mutual fund or other investments you hold. B. Investment Advisory Consulting Services/ Retirement Plan Investment Management Services I. INVESTMENT CONSULTING SERVICES ADVISORY FEES* The annual fee will be invoiced quarterly, in arrears, based on the market value of the funds under advisement on the last business day of the previous quarter. Market Value of Plan Assets All Assets Minimum Annual Fee Advisory Fee 0.09% $1,250 II. RETIREMENT PLAN 3(21) INVESTMENT ADVISORY FEES* The annual fee will be invoiced quarterly, in arrears, based on the market value of the funds under advisement on the last business day of the previous quarter. Market Value of Plan Assets First $2,500,000 Next $2,500,000 Next $10,000,000 Next $10,000,000 Over $25,000,000 Minimum Annual Fee Advisory Fee 0.35% 0.25% 0.15% 0.10% 0.05% $7,500 III. RETIREMENT PLAN 3(38) INVESTMENT ADVISORY FEES* The annual fee will be invoiced quarterly, in arrears, based on the market value of the funds under advisement on the last business day of the previous quarter. Market Value of Plan Assets First $2,500,000 Next $2,500,000 Next $10,000,000 Next $10,000,000 Over $25,000,000 Minimum Annual Fee Advisory Fee 0.40% 0.30% 0.20% 0.15% 0.10% $5,000 *All fees may be negotiated based on the specific situation of the plan, asset levels and expected growth in the assets. In some circumstances, clients may be charged an hourly rate (negotiated) for certain plan related project work.The fees above reflect the current fee schedule. Existing clients may have a different fee schedule. Some clients’ fees may be higher or lower than those reflected in the current fee schedules. SPA may also receive certain fees from its custodial platforms and other revenue sharing compensation from mutual fund providers for providing shareholder services and administrative services for mutual funds purchased under the Plan. Any and all compensation and other revenue sharing payments received by SPA from these custodial platforms and/or mutual funds are used to offset administrative services and recordkeeping fees billed by SPA to its clients (as well as to offset fees charged by the Plan custodian or other professional service providers). Quarterly invoices sent to SPA clients illustrate total fees payable to SPA less revenue sharing income.To the extent revenue sharing income exceeds the fee payable, SPA may, at the Plan Sponsor’s discretion, set up a revenue recapture account or place the income into the applicable FORM ADV PART 2A FIRM BROCHURE 15  client’s Plan. Please note that the fees listed above are reflective of services provided by Sentinel Pension Advisors, LLC. only.The client may instruct Sentinel to work with a sub-advisor who will research, select and recommend securities for inclusion within the retirement plan. For instances in which a sub-advisor is utilized for this purpose, the sub-advisor may charge an additional fee and the overall fees may be higher than those listed above. All fees and services, including those of the sub-advisor, are detailed in the service agreement between all parties associated with the plan. Corporate Clients may terminate planning and/or consulting advisory services by providing sixty (60) days advance written notice to SPA. Any fees due to SPA for services provided prior to the date of termination will be payable upon receipt of invoice. C. FINANCIAL PLANNING/CONSULTING FEE SCHEDULE Financial Planning/Consulting Fees are negotiable and separate from advisory fees discussed elsewhere. Each Advisory Representative will negotiate a financial planning/consulting fee with the client and agree upon a fee prior to any services being rendered. Advisory Representatives may charge based on a flat or hourly fee.The fee will be based on several factors including but not limited to: the services requested by the client, the complexity of the client’s situation, the number of meetings required to complete the requested services, number of parties involved or other professionals, areas of review and analysis, staff resources, travel, time and research needed, and savings to the client as a result of the services. Further, Advisory Representatives may charge different fees based on the Advisory Representative and the level of experience. In general, hourly fees range up to $250 per hour.Typically, clients will be provided an estimate of the amount of time needed for the services. A deposit in the amount of one-half (1/2) of the estimated fee may be requested in advance. A client shall not be required to prepay more than $500 nor prepay six or more months in advance of the service. Alternatively, clients may negotiate with the Advisory Representative to pay hourly fees in arrears on a monthly basis promptly upon receipt of an invoice from the Advisory Representative. Clients may terminate, with written notice to SPA, planning and/or consulting advisory services within five (5) business days after entering into the advisory agreement, without penalty. After five (5) business days of entering into the financial planning advisory agreement, clients may terminate upon SPA’s receipt of a client’s written notice to terminate. Prepaid fees will be refunded to clients based on time spent by SPA multiplied by the hourly rate. After completion and presentation of the services no refunds will be issued. We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Focus Financial Partners, LLC (“Focus”) is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients.The revenue paid to UPTIQ also benefits UPTIQ Inc.’s investors, including Focus, our parent company. When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For non-residential mortgage loans made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from such third-party financial institutions. For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial institutions. For cash management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries that provide administrative and settlement services in connection with this program. As noted above, Flourish facilitates cash management solutions for our clients. When legally permissible, FORM ADV PART 2A FIRM BROCHURE 16  Flourish pays FSH a share of up to 0.10% of the total amount of cash held in Flourish cash accounts by our clients.This earned revenue is indirectly paid by our clients through an increased interest rate charged by the third-party financial institutions or, for cash balances, a lowered yield. FSH distributes this revenue to us when we are licensed to receive such revenue (or when no such license is required) and the distribution is not otherwise legally prohibited. Further information on this conflict of interest is available in Item 10 of this Brochure. VI. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT SPA does not charge performance-based fees or fees based on a share of capital gains on or capital appreciation of the assets of a client. In addition, SPA does not engage in side-by-side management (management of client accounts simultaneously with management of firm accounts). VII. TYPES OF CLIENTS SPA provides portfolio management services to individuals, pensions and profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. SPA requires a minimum account value of $25,000 for Individual Advisory Services and Managed Account Advisory Services “The SPA Wrap Fee Program”. All fees are negotiable subject to the specifics of each client and situation. SPA does not have a minimum for assets under management for the Investment Advisory Consulting Services/ Retirement Plan Investment Management Services. All minimums and fees are negotiable subject to the specifics of each client and situation. VIII. METHOD OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. METHOD OF ANALYSIS AND INVESTENT STRATEGIES SPA follows a disciplined research and evaluation process to determine appropriate investments for each model portfolio based on its target allocation. Along with this disciplined approach to managing client portfolios, SPA has the expertise and analytical tools to choose from the available universe of funds, collective investment trusts and mutual fund families with a wide range of investment managers.This provides SPA with the flexibility to analyze leading investments in each asset class and develop risk based portfolios for both individual clients offered through the SPA Wrap Fee Program and Life Style Model Portfolios offered to Retirement Plan Clients. SPA’s investment methods includeusing both quantitative and qualitative analysis to identify key money managers across a broad spectrum of asset classes with the objective of creating a unique roster of investment managers that will be included in client portfolios. Listed below are examples of selection criteria utilized in SPA’s proprietary screening process. One or more of these will be used in SPA’s analysis: Quantitative Factors: 1. Returns vs. peer funds: 1, 3, and 5 year total returns 2. Consistency of returns 3. Risk-adjusted measures of return: Sharpe Ration, Information Ratio, Up/Down Capture, Alpha, Batting Average 4. Volatility vs. Peers: Standard deviation of return 5. Expense ratio analysis Qualitative Factors: FORM ADV PART 2A FIRM BROCHURE 17  1. Management tenure and personnel 2. Investment process / decision making procedures 3. Style consistency 4. Portfolio or sector concentration 5. Fiduciary matters 6. Information availability Depending upon the model strategy managed by SPA, each investment within the portfolios is generally assigned to one of the following segments: 1. Fixed-Income: This segment is designed for stability and income generation.The underlying managers generally have the freedom to invest across multiple sectors of the bond market with the goal of generating strong long-term absolute total returns. 2. U.S. Equity: This segment will typically include domestic equity investments across the full range of market cap (small to large companies) and styles (value and growth). Weightings to individual managers will vary according to its market expectations. 3. Foreign Equity: This segment will typically include foreign equity investment strategies across the full range of market cap (small to large companies) and styles (value and growth). Weightings to individual managers will vary according to its market expectations. Emerging market investments and sector funds specializing in certain countries or regions are eligible in this segment. Portfolios managed by SPA may hold investments that aren’t categorized well within any of the above segments.These may be multi-asset class strategies, funds that are best classified as alternative investments or more narrowly focused investments limited to certain sectors. In these instances, the funds will be placed into one of the three core portfolio segments and reviewed under the same guidelines as the core investments. Whether SPA is developing investment strategies for individual investment portfolios offered through the SPA Wrap Fee Programs, or for the Lifestyle Model Portfolios offered to Retirement Plan Clients, the disciplined approach is followed.The main difference is that the universe of investments may be smaller for the Retirement Plan Clients versus Individual Clients.This is due to the fact that the investments offered within a retirement plan often are limited to those in which the plan sponsor, plan trustee and investment committee approve. Performance of each portfolio and the underlying strategies are regularly monitored by SPA’s investment commitee to determine if the investments continue to meet SPA’s strict criteria.The committee also monitors market conditions and, if needed, rebalances the portfolios to return them to their target asset allocation.For important information pertaining to the risks associated with investing in the various SPA Advisory programs, please review the section titled “Risk Factors” at the end of this section. For important information pertaining to the risks associated with investing in the various SPA Advisory programs, please review the section titled “Risk Factors” at the end of this section. For individual advisory services, SPA determines an investor’s profile by obtaining the appropriate financial and personal information from the investor including investment objectives, risk tolerance, and investment time horizon, as well as any restrictions (as agreed upon between SPA and the client) that the client wishes to impose upon the management of the portfolio.Through the data gathered on an investor’s profile and personal discussions in which goals and objectives based on a client’s particular FORM ADV PART 2A FIRM BROCHURE 18  circumstances are established, SPA develops a detailed investment plan and recommends an initial asset allocation best suited to achieve both portfolio and investment objectives. Typically, under this style of management, SPA will allocate the client’s assets among a portfolio of various mutual funds and/or ETFs taking into consideration the overall management style the client selects.The majority of investment vehicles are mutual funds; however some clients have the ability to self-direct investments in their retirement plans.They may also choose other investment vehicles in their brokerage accounts.The individual funds will be primarily selected by SPA on the basis of each fund’s performance history and investment objectives. Adjustments will be made to client portfolios periodically based on market conditions, client instructions or changes in client objectives. SPA will manage advisory accounts on either a discretionary or non- discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). For important information pertaining to the risks associated with investing in the various SPA Advisory programs, please review the section titled “Risk Factors” at the end of this section. B. RISK FACTORS Client understands, acknowledges and agrees that no assurance has been or can be given that client will achieve his or her investment objectives by accepting or implementing in whole or in part any investment strategy and/or allocation or any specific recommendation by SPA to purchase or sell any security or other investment or participate in the SPA Wrap Fee Programs or Lifestyle Model Portfolio Management. SPA cannot guarantee any level of performance or that clients will not experience a loss of account assets. Below is a list of material risks to SPA strategies:. SPA does not represent, warrant or imply that the services or methods of analysis used by SPA can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to major market corrections or crashes. No guarantees can be offered that clients’ goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by SPA will provide a better return than other investment strategies. The managers of the mutual funds and ETFs that SPA selects to participate in the Program or as part of a Lifestyle Model Portfolio may employ the same or substantially similar investment strategies, and may hold similar portfolios of investments, in other investment products or programs that they manage, such as managed account programs. Such other products or programs may be available through SPA or elsewhere.The costs and the services relating to the other products or programs in which these strategies are offered will differ. No guarantees can be offered that client’s goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by SPA will provide a better return than other investment strategies. Client has been informed, understands and acknowledges that unless stated otherwise in a supplemental disclosure document related to a specific investment or program, the investments in client’s Program account are not insured by the Federal Deposit Insurance Corporation (FDIC), are not deposits with or the obligation of or guaranteed by SPA or the Custodian or any of their affiliates, are subject to investment risk, including possible FORM ADV PART 2A FIRM BROCHURE 19  loss of principal invested, and that past performance is no guarantee of future results. Listed below are some examples: Market Risk The risk that the market price of may go up or down due to due to a variety of influences on the securities market. Managed account programs should be considered a long-term investment and thus long-term performance and performance consistency are the major goals. Mutual Fund Risk (Equity) Mutual funds are subject to risks similar to those of stocks, including market risk, which is the risk that investment returns will fluctuate and are subject to market volatility, so that an investor’s shares, when redeemed or sold, may be worth more or less than their original cost. International mutual funds are subject to fluctuations due to changes in a currency’s exchange rate and political risk. Mutual Fund Risk (Fixed Income) Fixed income mutual funds (bond funds) fluctuate with the bond market. Fixed income risks include: • Credit risk: the risk that a company or bond issuer may fail to pay principal and interest payments in a timely manner • Interest rate risk: the risk that the Market value of the bonds will go down when interest rated go up • Prepayment risk: the risk that a bond will be paid off early ETF Risk Risks associated with investing in ETFs: equity based ETFs are subject to risks similar to those of stocks, and fixed income based ETFs are subject to risks similar to those of bonds. Investment returns will fluctuate and are subject to market volatility, so that investor’s shares, then redeemed or sold, may be worth more or less that their original cost. Foreign-based ETFs have unique and greater risks than domestic-based ETFs. CIT Risk Risks associated with investing in CITs: Investments in CITs are not insured or guaranteed by any bank, the FDIC, or any other government entity. CITs are subject to risks similar to those of mutual funds, stocks, and fixed income assets. Investment returns will fluctuate and are subject to market volatility, so that investor’s units, when redeemed or sold, may be worth more or less that their original cost. Management Risk Risks associated in regard to the use of other managers, risks include the possibility of manager turnover, style drift, underperformance, size constraint, tax inefficiency, compliance, and fee changes. In addition, for alternative investments, private offerings, and certain other third-party managers, potential risk factors include lack of liquidity, lack of transparency, layering of fees, and other risks as identified by such managers in their disclosure documents. Cryptocurrency Risk Cryptocurrency (notably, bitcoin), often referred to as “virtual currency”, “digital currency,” or “digital assets,” operates as a decentralized, peer-to-peer financial exchange and value storage that is used like money. SPA prohibits the direct purchase of crypto-currency (e.g. Bitcoin), initial coin offering (ICO), distributed ledger technology, blockchain and any related products or pooled investment vehicles (collectively “Crypto-Assets). However, FORM ADV PART 2A FIRM BROCHURE 20  SPA may recommend Crypto-Assets through the purchase of ETFs or mutual funds. Clients may also have exposure to cryptocurrencies other than bitcoin. Cryptocurrency operates without central authority or banks and is not backed by any government. Even indirectly, cryptocurrencies may experience very high volatility and related investment vehicles may be affected by such volatility. As a result of holding cryptocurrency, certain products may also trade at a significant premium to NAV. Cryptocurrency is also not legal tender. Federal, state or foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing.The SEC has issued a public report stating U.S. federal securities laws require treating some digital assets as securities. Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers or malware. Due to its relatively recent launch, bitcoin has a limited trading history, making it difficult for investors to evaluate investments in this cryptocurrency. It is also possible that a cryptocurrency other than bitcoin, including cryptocurrencies in which clients have limited or no exposure to, could become materially popular and have a negative impact on the demand for and price of bitcoin. It is possible that another entity could manipulate the blockchain in a manner that is detrimental to the bitcoin network. Bitcoin transactions are irreversible such that an improper transfer can only be undone by the receiver of the bitcoin agreeing to return the bitcoin to the original sender. Digital assets are highly dependent on their developers and there is no guarantee that development will continue or that developers will not abandon a project with little or no notice. Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including cryptocurrencies, and their source code. Any threatened action that reduces confidence in a network’s long-term ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies. Many significant aspects of the U.S. federal income tax treatment of investments in bitcoin are uncertain and an investment in bitcoin may produce income that is not treated as qualifying income for purposes of the income test applicable to regulated investment companies. Cybersecurity Risk The computer systems, networks and devices used by SPA and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future.” FORM ADV PART 2A FIRM BROCHURE 21  IX. DISCIPLINARY INFORMATION There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business or the integrity of our management. X. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS The principal executive officers of SPA are also pension consultants and/or officers of Sentinel Benefits Group, LLC (‘’SBG’’), a third party administration firm for pension plans. SBG is affiliated with SPA through common ownership and control. SPA clients can choose to use the pension administration services of SBG. Fees for SBG’s pension administration services are in addition to SPA advisory fees. No SPA client is obligated to use SBG for pension administration services. SBG may recommend the advisory services of SPA to its clients.There is no referral fee arrangement between SPA and SBG. The principal executive officers of SPA are also agents, and/or officers of Sentinel Insurance Agency.These individuals are also independent agents for various insurance companies.Therefore, these individuals will be able to purchase insurance products for any client in need of such services.These individuals will be able to receive separate, yet typical compensation for the purchase of insurance products. SPA, its Advisory Representatives and related persons have a conflict of interest to recommend clients purchase insurance products since commissions may be earned in addition to fees for advisory services. Clients are not obligated to purchase insurance products through SPA or its Advisory Representatives. SPA has a compliance program in place to monitor the activities of its Advisory Representatives. Advisory Representatives may be sanctioned by SPA for taking advantage of a situation involving a conflict of interest and not acting within clients’ best interests. Neither Sentinel nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing persons. Clients are under no obligation to purchase or sell securities through SPA agents. However, if a client chooses to implement the recommendations, commissions may be earned by SPA agents (i.e. Sentinel Securities or Sentinel Insurance Agency) in addition to any fees paid for advisory services. SPA management and investment advisor representatives do not recommend or select other investment advisors for SPA clients. Commissions may be higher or lower at Sentinel Securities than at other broker-dealers. SPA Advisory Representatives may have a conflict of interest in having clients purchase securities and/ or insurance related products through Sentinel Securities, in that the higher their production with Sentinel Securities the greater potential for obtaining a higher pay-out on commissions earned. Further, Advisory Representatives may be restricted to only offering those products and services that have been reviewed and approved for offering to the public through Sentinel Securities. The principal executive officers and other related “employees” of SPA are officers, managers, and/or registered representatives of Sentinel Securities, a registered broker- dealer and FINRA member. Sentinel Securities is affiliated with SPA through common ownership and control.These individuals will be able to effect separate securities transactions for advisory clients and Sentinel Securities may receive separate and customary compensation for this activity and may pay a portion of the compensation to these individuals. In some circumstances, Sentinel Securities may receive customary compensation from mutual fund companies and/or variable annuity companies, including 12b-1 fees, for performing certain administrative and/or shareholder servicing related tasks associated with a SPA client’s investments in such securities. Sentinel Securities’s FORM ADV PART 2A FIRM BROCHURE 22  securities business is primarily limited to mutual fund shares and variable insurance contracts. SPA is a subsidiary of Focus Operating, LLC, which is a subsidiary of Focus Financial Partners, LLC (“Focus”). Focus also controls other registered investment advisors, broker- dealers, pension consultants, insurance firms, and other financial services firms (the “Focus Affiliates”).The Focus Affiliates may provide, among other services, wealth management, benefit and other investment consulting services that may serve individuals, families, employers, and institutions. Some Focus Affiliates also manage or advise limited partnerships, private funds, or limited liability companies as disclosed on their respective Forms ADV Schedule D. Focus Affiliates with whom SPA has a material business relationship are listed in SPA’s Form ADV Part 1 Schedule D, and below. Additional information about the Focus Affiliates is available at www.focusfinancialpartners.com. As noted in response to Item 4, SPA is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, SPA is a wholly-owned indirect subsidiary of Focus LLC. SPA may from time to time recommend services of other Focus affiliates to our clients. Please note that no financial incentives or compensation of any kind are exchanged between SPA and Focus affiliates with regard to mutual clients. Focus Financial Partners, Inc. is the sole managing member of Focus LLC. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”) and investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”). As a result, SPA is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles. SPA may recommend investments managed or advised by Focus Affiliates. Please note that no financial incentives or compensation of any kind are exchanged between SPA and Focus affiliates with regard to any recommended investments managed or advised by Focus Affiliates. SPA and Focus Partners Wealth, LLC (“FPW”) are both advisory firms owned by Focus. SPA and FPW have an agreement in place whereby FPW serves as a subadvisor to SPA for certain client retirement plans. SPA and the client enter an advisory agreement that specifies the discretionary and/or non-discretionary advisory services and duties to be delegated to FPW. Generally, FPW is responsible for investment recommendations and creating and maintaining model portfolios, individual fund choices, and asset allocation targets. SPA is generally responsible for fiduciary governance, participant services, and portfolio administration, including trading, rebalancing, and fiduciary and performance reporting. FPW, at its discretion, may participate in Sentinel’s investment meetings with clients. As the advisor to the client, SPA collects its quarterly advisory fee and remits 50% of such fee to FPW for its services. SPA and Mosaic Family Wealth Partners, LLC (“Mosaic”) are both advisory firms owned by Focus. SPA and Mosaic have an agreement in place whereby Mosaic serves as a subadvisor to SPA for certain client retirement plans. SPA and the client enter an advisory agreement that specifies the discretionary and/or non-discretionary advisory services and duties to be delegated to Mosaic. Generally, Mosaic is responsible for investment recommendations and creating and maintaining model portfolios, individual fund choices, and asset allocation targets. SPA is generally responsible for fiduciary governance, participant services, and portfolio administration, including trading, rebalancing, and fiduciary and performance reporting. Mosaic at its discretion, may participate in Sentinel’s investment meetings with clients. As the advisor to the client, SPA collects its quarterly advisory fee and remits 50% of such fee to Mosaic for its services. FORM ADV PART 2A FIRM BROCHURE 23  To the extent SPA employees who, in their registered representative capacity with Sentinel Securities, serve as broker of record for a qualified retirement plan (“Plans”), the registered representatives may recommend the purchase of a group annuity policy as the funding vehicle for the Plan through its affiliated insurance agency, Sentinel Insurance. In no event will such Plan also be a client of SPA. If a registered representative refers a Plan whose funding vehicle is a group annuity to Sentinel Insurance, the registered representative may be paid a portion of commissions received by Sentinel Insurance. SPA provides certain advisory services with respect to the accounts of Participants of Plans in connection with the investment advisory services that SPA provides to the plan sponsors of such Plans. In some instances, a participant may elect to transfer his/ her account (e.g., an IRA) out of the Plan to be managed separately by SPA. SPA may recommend the use of Sentinel Securities, LLC (and other brokers unaffiliated with SPA), who provide brokerage services, to such participant in such event. Under these circumstances, the participant may pay greater fees to SPA and commissions to the selected broker-dealer with respect to his/her account for the same services that the participant would have received had his/her account remained in the Plan.Thus, there may be a financial incentive for SPA (and/or its affiliated broker-dealer, Sentinel Securities, LLC) to encourage participants to transfer their accounts out of their respective Plans to be managed separately by SPA. Advice offered by SPA’s Advisory Representatives may involve investment in mutual funds. Mutual funds may carry loads (i.e. sales charges) that may be up-front or on a contingent deferred basis, or can be no-loads with no initial or contingent deferred sales charges. Clients are advised that some Advisory Representatives are registered representatives of Sentinel Securities, LLC. a registered broker-dealer, member of the Financial Industry Regulatory Authority (“FINRA”) and SIPC. Therefore, Advisory Representatives have a conflict of interest in recommending mutual funds that carry a load since such mutual funds will pay Advisory Representatives a commission should the purchase be made through Advisory Representatives. A conflict of interest may exist between the interests of SPA and/or its Advisory Representatives and the interests of the client in that SPA and Advisory Representatives offer financial planning and investment advisory services for a fee and also offer various securities products for which they may be paid a commission.The securities products available through SPA may be limited to certain products that have been reviewed and made available for offering through the broker/dealer with which Advisory Representatives may be registered representatives. Lower fees for comparable services may be available from other sources. Material conflicts of interest disclosed to the client in writing via this Form ADV, Part 2 could cause SPA or its Advisory Representatives to not render unbiased and objective advice. Clients are advised that the investment recommendations, and advice offered by SPA, are not legal recommendations or advice, nor does it constitute accounting advice. Clients should coordinate and discuss the impact of financial advice with their attorney and/or accountant. Clients are advised that it is necessary to inform SPA promptly with respect to any changes in the client’s financial situation and investment goals and objectives. Failure to notify SPA of any such changes could result in investment recommendations being made that are based upon inaccurate information, thus will not meet the needs of the client. The level of experience of Advisory Representatives will vary. Additionally, the fees charged by various Advisory Representatives will not exceed the fee schedules disclosed herein but may vary.Therefore, clients receiving similar services may pay higher or lower fees than another client depending on their Advisory Representative. A higher fee is not necessarily commensurate with the experience of the Advisory Representative. FORM ADV PART 2A FIRM BROCHURE 24  Advisory Representatives who are Registered Representatives of Sentinel Securities may receive trail commissions (i.e. 12b-1 fees) for a period of time. Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees may be initially paid to Sentinel Securities and a portion passed to the Advisory Representatives. The receipt of such fees could represent an incentive for Advisory Representatives to recommend funds with 12b-1 fees over funds that have no fees or lower fees. As a result, there is a potential conflict of interest. Some of the Firm’s Supervised Persons are licensed insurance brokers and may offer certain insurance products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that the Firm recommends the purchase of insurance products where its Supervised Persons may be entitled to insurance commissions or other additional compensation.The Firm has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations. Periodically, Focus Financial Partners, LLC (“Focus”), our parent company, holds partnership meetings and other industry and best-practices conferences, which typically include Focus firm and external attendees.These meetings provide sponsorship opportunities for asset managers, asset custodians, vendors and other third party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms, including Sentinel Pension Advisors, LLC., and facilitate access to our advisors and employees to discuss ideas, products and services.This could be deemed a conflict: the marketing and education activities conducted, and the access granted, at such meetings and conferences may lead advisors to focus on those conference sponsors in the course of their duties. Focus attempts to mitigate any such conflict by having the fees only go towards defraying the cost of such meeting or future meetings and not as revenue for itself or any affiliate. Conference sponsorship fees are not dependent on assets placed with any specific provider, or the revenue generated by asset placement. SPA also holds meetings and other industry and best-practices conferences, which typically include firm and external attendees.These meetings provide sponsorship opportunities for asset managers, asset custodians, vendors and other third party service providers. Sponsorship fees allow these companies to advertise their products and services to SPA and other attendees and facilitate access to our advisors and employees to discuss ideas, products and services.This could be deemed a conflict: the marketing and education activities conducted, and the access granted, at such meetings and conferences may lead advisors to focus on those conference sponsors in the course of their duties. SPA attempts to mitigate any such conflict by having the fees only go towards defraying the cost of such meeting or future meetings and not as revenue for itself or any affiliate. Conference sponsorship fees are not dependent on assets placed with any specific provider, or the revenue generated by asset placement. Principals of the Firm serve on advisory boards/councils for Charles Schwab & Co., Inc. and Fidelity Brokerage Services LLC (the “Panels”).The Panels consists of independent investment advisors that advise these firms on issues relevant to the independent advisor community.The Panels meet in person on average three to four times per year and conducts periodic conference calls on an as needed basis. Investment advisors are appointed to serve on the Panel by the sponsoring firm. At times, Panel members are provided confidential information about the firm’s initiatives. Panel members are required to sign confidentiality agreements and are not compensated. However, the firm may pay or reimburses panel members for the travel, lodging and meal expenses incurred in attending Panel meetings.The benefits received by our personnel by serving on the Panel do not depend on the amount of brokerage transactions directed to the firm. Clients should be aware, however, that the receipt of economic benefits in and of itself creates a potential conflict of interest. FORM ADV PART 2A FIRM BROCHURE 25  Cash and Cash Management Solutions We offer clients the option of obtaining certain financial solutions from unaffiliated third- party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). These third-party financial institutions are banks and non-banks that offer credit and cash management solutions to our clients, as well as certain other unaffiliated third parties that provide administrative and settlement services to facilitate UPTIQ’s cash management solutions. UPTIQ acts as an intermediary to facilitate our clients’ access to these credit and cash management solutions. Flourish acts as an intermediary to facilitate our clients’ access to cash management solutions. We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients.The revenue paid to UPTIQ also benefits UPTIQ Inc.’s investors, including Focus. When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For non-residential mortgage loans made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from the third-party financial institutions. For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial institutions. For cash management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries that provide administrative and settlement services in connection with this program. As noted above, Flourish facilitates cash management solutions for our clients. When legally permissible, Flourish pays FSH a revenue share of up to 0.10% of the total amount of cash held in Flourish cash accounts by our clients. This earned revenue is indirectly paid by our clients through an increased interest ratecharged by the third-party financial institutions for credit solutions or reduced yield paid by the providers of cash management solutions. FSH distributes this revenue to us when we are licensed to receive such revenue (or when no such license is required) and the distribution is not otherwise legally prohibited.This revenue is also revenue for FSH’s and our common parent company, Focus. Additionally, the volume generated by our clients’ transactions allows Focus to negotiate better terms with UPTIQ and Flourish which benefits Focus and us. Accordingly, we have a conflict of interest when recommending UPTIQ’s and Flourish’s services to clients because of the compensation to us and to our affiliates, FSH and Focus, and the transaction volume to UPTIQ and Flourish. We mitigate this conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our clients, including in this Brochure; and (2) offering UPTIQ’s and Flourish’s solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services. Additionally, we note that clients who use UPTIQ’s and Flourish’s services will receive product-specific disclosure from the third-party financial institutions and other unaffiliated third-party intermediaries that provide services to our clients. We have an additional conflict of interest when we recommend credit solutions to our clients because our interest in continuing to receive investment advisory fees from client accounts gives us a financial incentive to recommend that clients borrow money rather than liquidate some or all of the assets we manage. Credit Solutions Clients retain the right to pledge assets in accounts generally, subject to any restrictions imposed by clients’ custodians. While credit solution programs that we offer facilitate secured loans through third-party financial institutions, clients are free instead to work FORM ADV PART 2A FIRM BROCHURE 26  directly with institutions outside such programs. Because of the limited number of participating third-party financial institutions, clients may be limited in their ability to obtain as favorable loan terms as if the client were to work directly with other banks to negotiate loan terms or obtain other financial arrangements. Clients should also understand that pledging assets in an account to secure a loan involves additional risk and restrictions. A third-party financial institution has the authority to liquidate all or part of the pledged securities at any time, without prior notice to clients and without their consent, to maintain required collateral levels. The third-party financial institution also has the right to call client loans and require repayment within a short period of time; if the client cannot repay the loan within the specified time period, the third-party financial institution will have the right to force the sale of pledged assets to repay those loans. Selling assets to maintain collateral levels or calling loans may result in asset sales and realized losses in a declining market, leading to the permanent loss of capital.These sales also may have adverse tax consequences. Interest payments and any other loan-related fees are borne by clients and are in addition to the advisory fees that clients pay us for managing assets, including assets that are pledged as collateral.The returns on pledged assets may be less than the account fees and interest paid by the account. Clients should consider carefully and skeptically any recommendation to pursue a more aggressive investment strategy in order to support the cost of borrowing, particularly the risks and costs of any such strategy. More generally, before borrowing funds, a client should carefully review the loan agreement, loan application, and other forms and determine that the loan is consistent with the client’s long-term financial goals and presents risks consistent with the client’s financial circumstances and risk tolerance. We use UPTIQ to facilitate credit solutions for our clients. Cash Management Solutions For cash management programs, certain third-party intermediaries provide administrative and settlement services to our clients. Engaging the third-party financial institutions and other intermediaries to provide cash management solutions does not alter the manner in which we treat cash for billing purposes. Clients should understand that in rare circumstances, depending on interest rates and other economic and market factors, the yields on cash management solutions could be lower than the aggregate fees and expenses charged by the third-party financial institutions, the intermediaries referenced above, and us. Consequently, in these rare circumstances, a client could experience a negative overall investment return with respect to those cash investments. Nonetheless, it might still be reasonable for a client to participate in a cash management program if the client prefers to hold cash at the third-party financial institutions rather than at other financial institutions (e.g., to take advantage of FDIC insurance). We use UPTIQ and Flourish to facilitate cash management solutions for our clients. XI. CODE OF ETHICS, PARTICIPATION or INTEREST IN CLIENT TRANSACTIONS, and PERSONAL TRADING A. Code of Ethics SPA has in place a Code of Ethics that provides for SPA and its Advisor Representatives to exercise its fiduciary duty to clients to act in the best interest of the client and always place the client’s interests first and foremost. SPA takes seriously its compliance and regulatory obligations and requires all staff to comply with such rules and regulations as well as SPA’s policies and procedures. FORM ADV PART 2A FIRM BROCHURE 27  The Code of Ethics (the “Code”) has been adopted by SPA and is designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940, as amended (“Advisers Act”).The Code establishes rules of conduct for all employees of SPA and is designed to, among other things; govern personal securities trading activities in the accounts of employees.The Code is based upon the principle that SPA and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. A copy of the SPA’s Code is available to clients and potential clients upon request. The Code is designed to ensure that the high ethical standards long maintained by SPA continue to be applied.The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct.The excellent name and reputation of our firm continues to be a direct reflection of the conduct of each employee. Pursuant to Section 206 of the Advisers Act, both SPA and its employees are prohibited from engaging in fraudulent, deceptive or manipulative conduct. Compliance with this section involves more than acting with honesty and good faith alone. In meeting its fiduciary responsibilities to its clients, SPA expects every employee to demonstrate the highest standards of ethical conduct for continued employment with SPA. Strict compliance with the provisions of the Code shall be considered a basic condition of employment with SPA.SPA reputation for fair and honest dealing with its clients has taken considerable time to build.This standing could be seriously damaged as the result of even a single securities transaction being considered questionable in light of the fiduciary duty owed to our clients. SPA employees are urged to seek the advice of the Chief Compliance Officer for any questions about the Code or the application of the Code to their individual circumstances. A material breach of the provisions of the Code by an employee may constitute grounds for disciplinary action, including termination of employment with SPA. B. Privacy Policy SPA recognizes and respects the privacy of each of its customers and their expectations for confidentiality.The protection of customer information is of fundamental importance in our operation and SPA takes seriously its responsibility to protect nonpublic personal information. SPA collects, retains and uses information that assissts SPA in providing the best service possible.This information comes from the following sources: • Account applications and other required forms • Written, oral, electronic or telephonic communications an • Account and transaction histories with us, our affiliates, or others SPA does not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. SPA restricts access to nonpublic personal information about you to those employees, affiliates, and service providers who need to know that information to provide SPA products or services to you. SPA requires that these entities limit the use of the information provided to the purposes for which it was disclosed and as permitted by law. SPA maintains physical, electronic, and procedural safeguards that comply with federal standards to guard your FORM ADV PART 2A FIRM BROCHURE 28  nonpublic personal information. C. Participation or Interest in Client Transactions and Personal Trading It is the express policy of SPA that no person employed by SPA may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, and therefore, preventing such employees from benefiting from transactions placed on behalf of advisory accounts. SPA or individuals associated with SPA may buy or sell securities identical to those recommended to customers for their personal accounts. Additionally, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. As these situations represent a conflict of interest, SPA has established the following restrictions in order to ensure its fiduciary responsibilities: 1. A director, officer or employee of SPA shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No person of SPA shall prefer his or her own interest to that of the advisory client. 2. SPA maintains a list of all securities holdings and anyone associated with this advisory practice with access to advisory recommendations.These holdings are reviewed on a regular basis by an appropriate officer/individual of SPA. 3. All clients are fully informed that certain individuals may receive separate compensation when effecting transactions during the implementation process. 4. SPA emphasizes the unrestricted right of the client to decline to implement any advice rendered, except in situations where SPA is granted discretionary authority of the client’s account. 5. SPA emphasizes the unrestricted right of the client to select and choose any broker or dealer, and/or insurance company (s)he wishes. 6. SPA requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 7. Any individual not in observance of the above may be subject to termination. XII. BROKERAGE PRACTICES For clients in need of brokerage or custodial services, SPA will recommend the use of any number of broker dealers including Sentinel Securities, LLC, Fidelity Brokerage Services, LLC., or Charles Schwab & Co., Inc., all FINRA registered broker dealers.The factors considered by SPA when recommending a broker are the broker’s ability to provide professional services, SPA’s experience with the broker, the broker’s reputation, and the broker’s financial strength, among other factors. While there is no direct linkage between the investment advice given and implementation of securities transactions through these arrangements, economic benefits are received which would not be received if SPA did not give investment advice to clients.These benefits include: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk serving participants exclusively; ability to have investment advisory fees deducted directly from client account; access, for a fee, to an electronic communication network for client order entry and account information; receipt of compliance publications; and access to mutual funds which generally require significantly higher minimum initial investments or are generally available only to institutional investors. FORM ADV PART 2A FIRM BROCHURE 29  The benefits received through participation in the SPA program or the Fidelity program may or may not depend upon the amount of transactions directed to, or amount of assets custodied. Employees of SPA who are registered representatives of Sentinel Securities, LLC receive commissions for serving as broker of record for certain Plans. Such commissions flow through Sentinel Securities, LLC to the individual registered representative. A.1. Research and Other Soft Dollar Benefits SPA does not receive research or other products or services other than execution from a broker-dealer or third party in connection with client securities transactions (“soft dollar benefits”). A.2. Brokerage For Client Referrals SPA does not consider, in selecting or recommending broker-dealers, whether SPA or a related person of SPA receives client referrals from a broker-dealer or third party. A.3. Directed Brokerage Sentinel does not routinely recommend, request, or require that a client direct Sentinel to execute transactions through a specified broker-dealer. While clients may direct Sentinel to utilize specified brokerage firms for trade executions, where clients wish to direct the use of a particular broker dealer, it should be understood that SPA will not have authority to negotiate commissions or obtain volume discounts, and best execution may not be achieved. In addition, a disparity in commission charges may exist between the commissions charged to other clients. Thus, where clients direct brokerage transactions may cost them more than if executed utilizing SPA’s best execution practices. A.4. Trade Aggregation (bundling trades to obtain volume discounts on execution costs) ETFs do not sell or redeem their individual shares (“ETF shares”) at net asset value (“NAV”) like a mutual fund does. Instead, financial institutions purchase and redeem ETF shares directly from the ETF, but only in large blocks called “creation units” (e.g., blocks of 25,000 or 50,000 shares).These financial institutions are generally required to enter into an agreement with the particular ETF, ETF sponsor or principal underwriter in order to effect transactions in creation units for the ETF shares (such a financial institution is referred to as an “Authorized Participant”). Consistent with firm policy regarding Trade Aggregation, SPA, through Sentinel Securities, LLC, may from time to time effect transactions in ETF shares large enough to satisfy the creation unit criteria for an ETF. Since Sentinel Securities is not an Authorized Participant, these transactions may not be executed directly with the ETF. Instead, these transactions are executed through a financial institution that is an Authorized Participant with respect to the particular ETF. In doing so, clients will generally not be able to purchase or sell ETF shares at NAV since there are additional costs associated with trading through the third party financial institution.These costs are borne by clients and are reflected as either a mark-up or mark-down (depending upon whether the transaction is a purchase or sale) in the price per ETF shares or in a separate commission or charge. XIII. REVIEW OF ACCOUNTS Account assets for investment advisory clients are supervised continuously and formally reviewed at least annually by the Advisory Representative assigned to the account.The review process will include, but is not limited to: comparing the current asset allocation to the asset allocation models, or the recommended asset allocation and evaluating the need for rebalancing. Additional account reviews may be triggered by any of the following events; a specific client request, deposit or withdrawal of client funds, or a FORM ADV PART 2A FIRM BROCHURE 30  change in the client’s stated goals or objectives. Clients will receive, at a minimum, quarterly reports furnished by SPA for the ManagedChoice IRA Program. Account activity in any given month will generate an account statement for that month. XIV. CLIENT REFERRALS AND OTHER COMPENSATION Sentinel has arrangements in place with certain third parties, called promoters, and another Focus partner firm, under which the third parties and the Focus partner firm each serves as a promoter and refers clients to us in exchange for a percentage of the advisory fees we collect from such referred clients. Such compensation creates an incentive for these promoters to refer clients to us, which is a conflict of interest for the promoters. Additionally, the Focus partner firm, like us, is an indirect wholly owned subsidiary of Focus LLC and is therefore under common control with us.The Focus partner firm’s successful referral of clients to us, rather than to an unaffiliated investment manager, increases our compensation and the revenue to Focus LLC, relative to a situation in which the Focus partner firm refers clients to an unaffiliated investment manager. As a consequence, Focus LLC has a financial incentive to encourage the Focus partner firm to refer clients to us, which also creates a conflict of interest with those referred clients. Rule 206(4)-1 under the Advisers Act addresses this conflict of interest by, among other things, requiring disclosure of whether the promoter is a client or a non-client and a description of the material conflicts of interest and material terms of the compensation arrangement with the promoter. Accordingly, we require promoters, including the Focus partner firm, to disclose to referred clients, in writing: whether the promoter is a client or a non-client; that the promoter will be compensated for the referral; the material conflicts of interest arising from the relationship and/or compensation arrangement; and the material terms of the compensation arrangement, including a description of the compensation to be provided for the referral. Any such referral fee shall be paid solely from the Program fee paid to SPA, and shall not result in any additional charge to the client. If the client is introduced to SPA by an unaffiliated promoter, the promoter shall provide the client with a copy of Form ADV Part 2, the Form CRS, the Wrap Fee Program brochure and a copy of the disclosure statement between SPA and the promoter containing the terms and conditions of the solicitation arrangement, including compensation. Any affiliated promoter of SPA shall disclose the nature of his/ her relationship to prospective clients at the time of the solicitation and will provide all prospective clients with a copy of the Form ADV Part 2, the Form CRS and Wrap Fee Program brochure at the time of the solicitation. SPA’s principal executive officers and advisor representatives, from time to time, receive incentive awards or non-cash compensation for the recommendation/ introduction of investment products. While these individuals endeavor at all times to put the interest of the clients first as part of SPA’s fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest, and may affect the judgment of these individuals when making recommendations. All non-cash compensation must be disclosed to and, in certain instances, approved by the SPA Compliance Department.The SPA Compliance Department reviews and tracks all non-cash compensation or incentive awards provided to any SPA investment advisory representative from an outside firm to ensure compliance with all applicable rules and regulations. Certain mutual funds and variable annuities in which you are invested pay marketing fees, service fees, including shareholder service fees, 12b-1 fees, to SPA or Sentinel Securities, LLC our affiliated broker/dealer for marketing assistance or the performance of certain administrative tasks associated with making an investment in such fund or annuity. Any such fees received by us will not be credited against the fees otherwise payable by individual clients to us. Our employees or associated persons on occasion are invited to attend seminars and meetings with the costs associated with such meetings borne by a sponsoring FORM ADV PART 2A FIRM BROCHURE 31  brokerage firm or other party extending the invitation. In addition, certain employees of SPA hold securities licenses at and are deemed “registered representatives” of Sentinel Securities. From time to time, such employees may act in their “registered representative” capacity as “broker of record” for a Plan. Pursuant to such arrangement, the registered representative will receive commission compensation from the Plan. In all cases, whether acting through SPA or as a registered representative of Sentinel Securities, the employee (who is a registered representative) does not have discretion over any client’s account. In connection with certain retirement plans, SBG may also receive certain fees from its custodial platforms and other revenue sharing compensation from mutual fund providers for providing shareholder services and administrative services for mutual funds purchased under the Plan. Any and all compensation and other revenue sharing payments received by SPA from these custodial platforms and/or mutual funds are used to offset administrative services and recordkeeping fees billed by SBG to its clients (as well as to offset fees charged by the Plan custodian or other professional service providers). Quarterly invoices sent to SPA/SBG clients illustrate total fees payable to SPA or SBG less revenue sharing income.To the extent revenue sharing income exceeds the fee payable to SPA or SBG will, at the plan sponsor’s discretion, set up a revenue recapture account or place the income into the applicable client’s Plan. SPA’s parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus holds partnership meetings and other industry and best-practices conferences, which typically include SPA, other Focus firms and external attendees.These meetings are first and foremost intended to provide training or education to personnel of Focus firms, including SPA. However, the meetings do provide sponsorship opportunities for asset managers, asset custodians, vendors and other third party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms, including SPA. Although the participation of Focus firm personnel in these meetings is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and the access granted, at such meetings and conferences could cause SPA to focus on those conference sponsors in the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate, including SPA. Conference sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset placement. The following entities have provided conference sponsorship to Focus from January 1, 2025 to February 1, 2026: • • • • • • • • • • • • • • Addepar, Inc. AQR Capital Management, LLC Bigelow LLC BlackRock, Inc. BOWS Administrator LLC (Brookfield Oaktree Wealth Solutions) Capital Integration Systems LLC (CAIS) Charles Schwab & Co., Inc. Cliffwater LLC Dimensional Fund Advisors LP Dinsmore Compliance Services, LLC (DCS) Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates) Edgewood Partners Insurance Center (EPIC) (includes Vanbridge) Fidelity Brokerage Services LLC (includes FIAM and Wealthscape) Flourish Financial LLC FORM ADV PART 2A FIRM BROCHURE 32  • Pacific Investment Management Company LLC (PIMCO) Pinnacle Insurance & Financial Services, LLC Practifi, Inc. Franklin Templeton Distributors LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and CANVAS) • Jackson National Life Distributors LLC • K&L Gates LLP • Lord, Abbett & Co. LLC • Nuveen Securities, LLC • Orion Advisor Solutions, Inc. • • • • Quantinno Capital Management LP (includes TaxEdge and DEALS (Direct • • • • • • • Equity Active Long Short)) RedBlack Software, LLC (includes intelliflo) SmartAsset Advisors LLC Stone Ridge Asset Management LLC The Vanguard Marketing Corporation, Inc. T. Rowe Price Investment Services, Inc. TriState Capital Bank VRGL Inc. You can access updates to the list of conference sponsors on Focus’ website through the following link: https://www.focusfinancialpartners.com/conference-sponsors/ Certain of SPA’s personnel participated in an advisor coaching program (the “Program”) organized by Focus and conducted by a professional coach.The Program is first and foremost intended to provide training or education to personnel of Focus firms, including SPA. However, the Program does provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms, including SPA. Although the participation of Focus firm personnel in the Program is not preconditioned on the achievement of a sales target for any Program sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and the access granted, at the Program could cause SPA to focus on the Program sponsors in the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the Program or future Programs and not as revenue for itself or any affiliate, including SPA. Program sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset placement. XV. CUSTODY SPA does not take physical custody of client accounts. Client assets must be maintained at a qualified custodian, such as a broker-dealer, who send their clients account statements at least quarterly. SPA has legal authority over client assets when we have the authority to debit our fees at the account custodian. We strongly encourage clients to carefully review the account statements they receive from the custodian, which will show the debiting of our fees, and to contact the Chief Compliance Officer if they have any questions about the debits to their accounts. We also could be deemed to have legal authority over client assets when Sentinel Benefits Group, LLC. (SBG), our affiliated Third-Party Administrator and Recordkeeper entity, has the authority to direct qualified custodians to disburse retirement plan assets to plan participants. We engage an independent auditor to verify the advisory client assets over FORM ADV PART 2A FIRM BROCHURE 33  which SBG has custody through surprise examination. XVI. INVESTMENT DISCRETION SPA may receive discretionary authority from the client at the outset of an advisory relationship to select the identity, timing and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. Any limitations on this discretionary authority shall be included in the advisory agreement. Clients may change/ amend these limitations as required. Such amendments shall be submitted in writing. XVII. VOTING CLIENT SECURITIES It is SPA’s longstanding policy that each client is responsible for voting all of the proxies related to the securities held in his/her account. For the advisory clients of SPA who were clients of Alliance Benefit Group Portfolio Strategies (“ABG PS”) prior to January 02, 2020, it is noted that ABG PS had a limited number of clients whose advisory contract called for ABG PS to vote client securities on behalf of its clients.Therefore, in light of these limited pre-existing arrangements, SPA will vote client securities on behalf of such clients. This “grandfathering” policy applies only to the aforementioned groups of clients. When SPA does in fact accept such responsibility, it will only cast proxy votes in a manner consistent with the best interest of its clients. Absent special circumstances, which are described in SPA’s Proxy Voting Policies and Procedures, all proxies will be voted consistent with guidelines established and described in SPA’s Proxy Voting Policies and Procedures, as they may be amended from time-to-time. A client may contact SPA to request information about how SPA voted proxies for their securities or to get a copy of SPA’s Proxy Voting Policies and Procedures. A brief summary of SPA’s Proxy Voting Policies and Procedures is as follows: • SPA generally will vote proxies according to SPA’s then current Proxy Voting Guidelines.The Proxy Voting Guidelines include many specific examples of voting decisions for the types of proposals that are most frequently presented, including composition of the board of directors, approval of independent auditors, management and director compensation, anti-takeover mechanisms and related issues, changes to capital structure, corporate and social policy issues, and issues involving mutual funds. • Although the Proxy Voting Guidelines are followed as a general policy, certain issues are considered on a case-by-case basis based on the relevant facts and circumstances. Since corporate governance issues are diverse and continually evolving, SPA is committed to spending sufficient time and resources to monitor these changes. • Clients cannot direct SPA’s vote on a particular solicitation but can revoke SPA’s authority to vote proxies. In situations where there is a conflict of interest in the voting of proxies due to business or personal relationships that SPA maintains with persons having an interest in the outcome of certain votes, SPA takes appropriate steps to ensure that its proxy voting decisions are made in the best interest of its clients and are not the product of such conflict. XVIII. FINANCIAL INFORMATION SPA has not attached a balance sheet for its most recent fiscal year because it does not require prepayment of more than $1,200 in fees per client and six or more months in FORM ADV PART 2A FIRM BROCHURE 34  advance. SPA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. XIX. REQUIREMENTS FOR STATE REGISTERED ADVISERS Not Applicable FORM ADV PART 2A FIRM BROCHURE 35  FORM ADV PART 2A FIRM BROCHURE 36 

Sentinel Pension Advisors, LLC 100 Quannapowitt Parkway Wakefield, MA 01880 Phone: 781.914.1361 Fax: 781.213.6742 Website: www.sentinelgroup.com SPA WRAP PROGRAM FORM ADV Part2A Appendix 1: The Wrap Fee Brochure This brochure provides investors with information about Sentinel Pension Advisors, LLC (“SPA”) and the SPA Wrap Program (“SPA Program” or “Program”) that should be considered before becoming a client of the SPA Program. This information has not been approved or verified by any state or federal governmental authority. This wrap fee program brochure provides information about the qualifications and business practices of Sentinel Pension Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 781-914-1361.The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Sentinel Pension Advisors, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Questions? Contact us anytime at: P: 781.914.1361 F: 781.213.6742 E: compliance@sentinelgroup.com The SPA Program is sponsored by: Sentinel Pension Advisors LLC. 100 Quannapowitt Parkway, Wakefield, MA 01880 March 31, 2026 1  1I. MATERIAL CHANGES Annual Update This brochure is filed as the annual update to the Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure. The annual update occurred on March 31, 2026. The Material Changes section of this brochure will be updated annually, and when material changes occur. Material Changes Since the Last Update There have not been any material changes since the last update. SPA WRAP PROGRAM 2  III. TABLE OF CONTENTS II. MATERIAL CHANGES ................................................................................................. 2 III. TABLE OF CONTENTS ............................................................................................... 3 IV. SERVICES, FEES AND COMPENSATION ................................................................... 4 V. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS .......................................... 13 VI. PORTFOLIO MANAGER SELECTION AND EVALUATION ................................... 13 V.II CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ..................... 14 VIII. CLIENT CONTACT WITH PORTFOLIO MANAGERS .......................................... 15 IX. ADDITIONAL INFORMATION ............................................................................... 15 SPA WRAP PROGRAM 3  IV. SERVICES, FEES AND COMPENSATION The SPA Wrap Fee Program (“Program”) is a fee-based program sponsored by Sentinel Pension Advisors, LLC. (“SPA”). Under the Program, SPA assists clients to develop, monitor, and manage a custom-tailored investment portfolio to help achieve the client’s investment objectives. The client grants discretionary authority over the client’s assets to SPA to buy, sell and trade investment vehicles which may include no-load and select load-waived mutual funds, exchange-traded funds (“ETFs”) and other securities approved for the Program (including stocks, bonds and options) and to liquidate previously purchased load mutual funds, stocks, bonds, options, ETFs and other investments; except for the fees related to the Program itself, clients pay no transaction fees or commissions. Thus, an account with more frequent trades, will, generally, pay less overall fees, than in an account type that would charge transaction fees and commissions to clients. Conversely, an account with less frequent trading may incur higher fees in this Program, than if it were invested in another program. A portion of the fees paid to SPA are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. Some custodians have introduced programs that eliminate transaction-based fees for trades of equities and exchange-traded funds (ETF’s). For equities and ETFs that are no longer subject to these transaction fees, SPA is no longer paying those transaction costs on behalf of clients and thereby benefits from a reduction in expenses associated with its wrap program. Although this change does not impose any new costs on clients, it does reduce the economic benefit of participating in a wrap program. SPA follows a disciplined research and evaluation process to determine appropriate investments for each model portfolio based on its target allocation. Along with this disciplined approach to managing client portfolios, SPA has the expertise and analytical tools to choose from thousands of funds and fund families with a wide range of investment managers. This provides SPA with the flexibility to analyze leading investments in each asset class and develop risk-based portfolios designed to develop investment strategies used by three model portfolios offered by the Program. The SPA Program diversified portfolios provide clients with access to professional investment management services to help them invest confidently for their future. Each portfolio is created with SPA’s in-depth analysis and screening criteria. There are currently nine model portfolios within the program – Moderate, Moderate Plus, Balanced, Growth, Moderate ESG, Balanced ESG, Growth ESG, Municipal Income, and Qualified Income – so clients can select the portfolio that will work best for their investment goals. Each of the model portfolios is comprised of a different mix of investments depending upon the criteria shown below. A SPA Advisory Representative can assist clients in their decision regarding which portfolio most closely matches their investment strategy. A. Investment Portfolios Moderate Portfolio: Account objective is to pursue total return with consideration for both income generation and capital growth. The portfolio typically invests the majority of assets in fixed-income strategies. The remaining allocations will be divided among other asset classes. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current market conditions and their expectations for future performance. You should consider this portfolio if you: • Have a short/intermediate-term investment time horizon • Seek a balance between income generation and growth of capital as the primary SPA WRAP PROGRAM 4  objective • Can tolerate a low-to-medium level of principal volatility Moderate Plus Portfolio: Account objective is to pursue total return with consideration for both income generation and capital growth. The portfolio typically invests the majority of assets in fixed-income strategies. The remaining allocations will be divided among other asset classes. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current market conditions and their expectations for future performance. You should consider this portfolio if you: • Have an intermediate-term investment time horizon • Seek a balance between income generation and growth of capital as the primary objective • Can accept levels of risk below that of the equity markets, but greater than the fixed income market Moderate ESG Portfolio: Account objective is twofold: 1) to pursue total return with consideration for both income generation and capital growth by typically investing the majority of the portfolio’s assets in U.S. and foreign fixed income strategies. The remaining allocations will be divided among other asset classes. 2) to invest in designated environment, social and governance (“ESG”) targeted strategies as prudently available and defined by the underlying strategies’ investment advisor. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current market conditions and their expectations for future performance. You should consider this portfolio if you: • Have an intermediate/long-term investment time horizon • Seek a balance between income generation and growth of capital with a greater focus on income generation • Seek a portfolio with a focus on targeting investments in ESG related sectors and industries • Can tolerate a medium to high level of principal volatility Balanced Portfolio: Account objective is to pursue total return with consideration for both capital growth and income generation. The portfolio typically invests the majority of the portfolio’s assets in U.S. and foreign equity strategies. The remaining allocations will be divided among other asset classes. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current marketing conditions and their expectations for future performance. You should consider this portfolio if you: • Have an intermediate/long term investment time horizon • Seek a balance between growth of capital and current income, with a greater focus on capital growth • Can tolerate a medium to high level of principal volatility Balanced ESG Portfolio: Account objective is twofold: 1) to pursue total return with consideration for both capital growth and income generation by typically investing the majority of the portfolio’s assets in U.S. and foreign equity strategies. The remaining allocations will be divided among other asset classes. 2) to invest in designated environment, social and governance (“ESG”) targeted strategies as prudently available and defined by the underlying strategies’ investment advisor. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current market conditions and their expectations for future performance. You should consider this portfolio if you: SPA WRAP PROGRAM 5  • Have an intermediate/long-term investment time horizon • Seek a balance between growth of capital and current income, with a greater focus on capital growth Seek a portfolio with a focus on targeting investments in ESG related sectors and industries • Can tolerate a medium to high level of principal volatility Growth Portfolio: Account objective is to pursue capital growth by typically investing the majority of the portfolio’s assets in U.S. and foreign equity strategies. The remaining allocations will be divided among other asset classes. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current market conditions and their expectations for future performance. You should consider this portfolio if you: • Have an intermediate/long term investment time horizon • Seek growth of capital as the primary objective, with minor consideration given to current income • Can tolerate a higher level of principal volatility Growth ESG Portfolio: Account objective is twofold: 1) to pursue total return with consideration for both capital growth and income generation by typically investing the majority of the portfolio’s assets in U.S. and foreign equity strategies. The remaining allocations will be divided among other asset classes. 2) to invest in designated environment, social and governance (“ESG”) targeted strategies as prudently available and defined by the underlying strategies’ investment advisor. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current market conditions and their expectations for future performance. You should consider this portfolio if you: • Have an intermediate/long-term investment time horizon • Seek a growth of capital as the primary objective with income generation as a secondary consideration • Seek a portfolio with a focus on targeting investments in ESG related sectors and industries • Can tolerate a medium to high level of principal volatility Municipal Income Portfolio: Account objective is to pursue total return with an emphasis on market-driven income generation followed by capital growth by typically investing the majority of the portfolio’s assets in fixed-income strategies. The remaining allocations will be divided among other asset classes. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current market conditions and their expectations for future performance. You should consider this portfolio if you: • Have a short/intermediate-term investment horizon • Primarily seek market-driven income generation • Can tolerate a low to medium level of principal risk volatility Qualified Income Portfolio: Account objective is to pursue total return with an emphasis on market-driven income generation followed by capital growth by typically investing the majority of the portfolio’s assets in fixed-income strategies. The remaining allocations will be divided among other asset classes. SPA has discretion to increase or decrease the amount allocated to any given asset class based on current market conditions and their expectations for future performance. You should consider this portfolio if you: SPA WRAP PROGRAM 6  • Have a short/intermediate-term investment horizon • Primarily seek market-driven income generation • Can tolerate a low to medium level of principal risk volatility B. Strategic Portfolio Segments Depending upon the model strategy managed by SPA, each investment within the portfolios is generally assigned to one of the following segments: 1. Fixed-Income: This segment is designed for stability and income generation. The underlying managers generally have the freedom to invest across multiple sectors of the bond market with the goal of generating long-term absolute total returns. 2. U.S. Equity: This segment will typically include domestic equity investment strategies across the full range of market cap (small to large cap companies) and styles (value and growth). Weightings to individual managers will vary according to market expectations. 3. Foreign Equity: This segment will typically include foreign equity investment strategies across the full range of market cap (small to large cap companies) and styles (value and growth). Weightings to individual managers will vary according to market expectations. Emerging market investments and sector funds specializing in certain countries or regions are eligible in this segment. Portfolios managed by SPA may hold investments that aren’t categorized well within any of the above segments. These may be multi-asset class strategies, funds that are best classified as alternative investments or more narrowly focused investments limited to certain sectors. In these instances, the funds will be placed into one of the three core portfolio segments and reviewed under the same guidelines as the core investments. C. Account Rebalancing SPA’s investment committee contributes their expertise to create and monitor a comprehensive strategy to help clients reach their investment goals by managing the asset allocation and the investment selection within each client portfolio. SPA monitors financial market conditions and the effect on investments and makes changes to keep the right balance of risk and return. As a result, client accounts will be reviewed and rebalanced as needed to maintain stated investments objectives. As detailed in the “Investment Selection Process” section, SPA’s investment committee follows a disciplined approach to research, evaluate and monitor client portfolios. Client accounts are typically rebalanced at least annually. Client account rebalancing may occur more frequently depending on the investment committee’s assessment of overall market conditions. Client account rebalancing will be accomplished by buying and selling Mutual Funds and ETFs that are approved by the Program, to the current suggested asset allocation. D. Terms The terms and conditions for client participation in the Program are set forth in the Client Agreement (as defined herein) and this wrap fee brochure, which is presented to all prospective and existing Program clients in accordance with the disclosure SPA WRAP PROGRAM 7  requirements of Rule 204-3 under the Advisers Act of 1940, as amended, and Form ADV (Uniform Application for Investment Adviser Registration). E. Purpose of the Program The Program enables clients to pursue their financial objectives through the active discretionary trading by SPA of a variety of investment vehicles including no-load mutual funds, select load-waived mutual funds and ETFs and other securities approved for the Program (including stocks, bonds and options), without transaction fees or brokerage commissions. F. Minimum Account Size SPA requires an account minimum of $25,000 for participation in the Program. However, SPA, in its sole discretion, may reduce the account minimum based upon certain criteria including, but not limited to, anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, and account composition. G. Brokerage and Custody The custodian of the client’s funds and securities under the Program (“Custodian”) is generally Pershing, LLC (Member NYSE/FINRA/SIPC) (“Pershing”). SPA does not have custody of any client funds or securities under the Program. By participating in the Program, each client instructs SPA to direct all orders for the purchase and sale of securities and other investments for the client’s account to Sentinel Securities, LLC, an SEC-registered broker-dealer (Member FINRA/SIPC) (“Sentinel Securities”) and SPA affiliate, as introducing broker for the client’s account. Sentinel Securities is an affiliate of SPA, and the principals of SPA are also registered representatives of Sentinel Securities. Sentinel Securities maintains a clearing arrangement with Pershing, LLC, a division of Bank of New York (“Pershing”) whereby Sentinel Securities clears securities transactions on a fully disclosed basis through Pershing as an introducing broker, and Pershing holds customer funds and/ or securities on behalf of Sentinel Securities brokerage customers for purposes of the Securities Investor Protection Act. Each client further directs Sentinel Securities to execute, clear and settle all client orders received by Sentinel Securities from SPA through Pershing. In connection with its clearing arrangement with Pershing, Sentinel Securities may receive (i) access to certain services provided by Pershing (including, without limitation, communication and content services, access to account and financial information, securities trading and other services), and (ii) distribution assistance fees (i.e., Rule 12b-1 fees and other shareholder servicing fees) from Pershing with respect to account balances for certain investments (including, among others, money market funds) held by Pershing for Sentinel Securities’ clients, which may include Program clients. Program clients may receive less favorable net prices, on transactions for their accounts than would otherwise be the case if SPA had the discretion to place orders for the purchase and sale of securities and other investments for client accounts through other broker-dealers. Furthermore, SPA may execute trades for the same securities for its other clients through other broker-dealers ahead of a Program client’s trades. By executing non-directed trades ahead of a Program client’s directed trades, such Program SPA WRAP PROGRAM 8  client may receive less favorable executions to SPA’s other clients including, but not limited to, less favorable prices due to, among other things, market movements. The Program fee includes compensation for brokerage services provided by Sentinel Securities as introducing broker for the client account as well as custodial, clearing, settlement and execution services (including brokerage commissions) provided by the designated broker-dealer. The Program fee does not cover, and clients will be responsible and charged for, certain additional fees and charges as set forth under “Additional Charges.” H. Suitability and Investment Strategy Prior to opening an account, SPA determines an investor’s profile for the Program by obtaining the appropriate financial and personal information from the investor including investment objectives, risk tolerance, and investment time horizon, as well as any reasonable restrictions that the client wishes to impose upon the management of the portfolio. SPA reviews the suitability of the investment strategy selected by the client based upon an assessment of the information provided by the client. Subsequently, SPA will invest client assets in accordance with the Model Portfolio selected by clients subject to any investment limitations specified by the client to SPA. Clients will have the opportunity (as agreed upon between SPA and the client) to restrict the types of investments which may be made on the client’s behalf. SPA specifically does not make any representations as to the abilities, experience or character of any of the managers of the mutual funds and ETFs that SPA selects as investments in the Program. The client is responsible for advising SPA of any changes to the client’s financial situation or objectives that may impact the prior determined investment strategy. SPA may accept or reject a wrap fee client for any reason, including but not limited to, such client’s investment goals and restrictions. The SPA Program may not be suitable for everyone. In determining whether the SPA Program is right for you, you should consider, among other things, your investment goals and strategies and your trading patterns, including the number, size and frequency of the transactions that SPA suggests for your Account. It is particularly important that you consider the costs and potential benefits of the SPA Program as compared to paying commissions on a per trade basis. The SPA Program may not be appropriate if you are a “Buy and Hold” investor or if you anticipate engaging in a lower level of trading activity, as greater transaction cost savings could be realized in a traditional pay-per-trade commission structure. I. Program Fees Clients pay a single asset-based fee. The Program fee will be set forth in the Client Agreement and is based on a percentage of the client’s total account assets under management in the Program. The Program fee is calculated and charged on a quarterly basis in advance (although in some cases, the Program fee may be calculated and charged in arrears instead). Our standard fee schedule for new clients is as follows: Asset Value (Annualized) Annual Fee* $25,000 to $249,999 1.50% SPA WRAP PROGRAM 9  from $250,000 to $499,999 1.25% from $500,000 to $999,999 1.00% from $1,000,000 to $4,999,999 0.85% from $5,000,000 and greater 0.60% *Specified rate applies only to assets in this tier. All fees may be negotiated based on the specific situation of the client’s financial plan and the asset levels and expected growth in the assets. Clients who engaged SPA prior to January 1, 2024, may be subject to fee schedules that use a blended fee rate rather than the tiered fee rate shown above. A minimum of $25,000 of assets under management is required for this service. However, this minimum may be negotiable under certain circumstances. In some circumstances, clients may be charged an hourly rate (negotiated) for certain financial plan related project work. SPA may, in its sole discretion, negotiate the Program fee paid by the client depending on considerations, including, but not limited to, the size of the client’s account, the amount of time that the client has had an account or accounts with SPA and/or Sentinel Securities, the total amount of business that the client conducts through SPA and/or Sentinel Securities, the types of investments and services provided, anticipated future earning capacity, anticipated future additional assets and other relevant criteria. Under the Program, an investor receives both investment advisory services and the execution, clearing and settlement of securities brokerage transactions for a single specified fee. Pershing, LLC provides Program clients with quarterly billing under its automated billing system at no additional fee to Program clients. An investor’s participation in the Program may cost the investor more or less than purchasing such advisory, brokerage and other services separately. In addition, the Program fee may be higher or lower than that charged by sponsors of other comparable wrap fee programs. For example, if there is heavy trading activity in an account and high custodial charges, the Program fee may cost an investor less than if purchasing advisory and custodial services separately and being charged brokerage commissions for each trade. Conversely, little trading activity and low custodial fees could result in the Program fee exceeding the cost of the services being charged separately. Furthermore, an investor could invest directly in the securities included in a Portfolio outside of the Program without incurring the Program fee, but would not receive the active management services SPA provides and may incur transaction charges. Program fees will be automatically deducted from the client’s account. Fee deductions will be funded from available cash or the proceeds of the sale of securities and other investments in the client’s account. Please see the Client Agreement for additional information regarding fees. J. Additional Charges The client may be responsible for paying certain charges in addition to the Program fees. Such charges include, but are not limited to, charges imposed directly by a mutual fund purchased for the client’s account, which shall be disclosed in the mutual fund’s A percentage of the advisory fees paid by the client is provided to the Advisory Representative for advisory services rendered. Similar investment advisory programs may be available from other investment advisors for a lower fee. The advisory fee (which includes transaction costs) may be more or less costly than paying for the services separately. Some of that factors that may cause a differential in cost are the investment advisory fees charged, the number of transactions for the account, the SPA WRAP PROGRAM 10  level of brokerage and other fees that would be payable if the client obtained the services available under the program individually. K. Termination Either the client or SPA may terminate the Client Agreement effective as of the end of a quarter upon advance written notice to the other prior to the end of such quarter. In the event of termination of the Client Agreement, SPA shall have no obligations whatsoever to recommend any action with respect to or to liquidate the assets in the client’s account. SPA shall be entitled to be paid its fees in connection with its services provided under the Client Agreement for the period to such effective termination. Thus, SPA may withhold a pro rata portion of the prepaid advisory fees for bona fide advisory services rendered during the quarter prior to such effective termination. Notwithstanding the foregoing, pursuant to applicable laws, SPA will refund excess advance payment to the extent that bona fide services have not been provided during such period. In addition, each client is required to notify SPA in the event that the client intends to withdraw assets in the client’s Program account to a level below the account minimum. Upon termination of any account, any prepaid unearned fees will be refunded based upon the number of days remaining in the quarter after the termination date, and any earned unpaid fees will be due and payable. L. Conflicts of Interest SPA, together with its affiliated entities (as discussed above under “Other Business Activities”), and in its capacity as an investment adviser, is routinely engaged in various securities transactions and trading activities for various clients and customers (in addition to the Program clients) which could create conflicts of interest among its duties to the Program clients and its duties to other clients. SPA, its affiliates, and each of their respective associated persons may purchase or sell securities for his, her or its own account that have been recommended to, or have been purchased or sold by, or on behalf of, clients in the Program. SPA, in accordance with applicable state and federal securities laws, rules and regulations, maintains and enforces written policies reasonably designed to: (1) prevent the misuse of material nonpublic information by SPA or any person associated with SPA, and (2) monitor the personal securities transactions of its associated persons to prevent any potential material conflicts of interest between SPA, any person associated with SPA, and any of its clients. SPA, its affiliates, and each of their respective associated persons may give advice or take action in performing their duties on behalf of a client, or for their own account, that differs from advice given or action taken on behalf of other clients. Neither SPA, nor its affiliates, nor any of their respective associated persons is obligated to buy, sell or recommend for any client any investment that such person may buy, sell or recommend for any other client or for their own account. Furthermore, as discussed above under “Brokerage and Custody,” Sentinel Securities may receive access to certain services provided by, and distribution assistance fees (i.e., Rule 12b-1 fees and other shareholder servicing fees) from, Pershing, LLC, with respect to account balances for certain investments (including, among others, money market funds) held by Pershing for Sentinel Securities’ clients, which may include Program clients. Sentinel Securities and/or SPA may receive similar services and fees from other Custodians and/or SPA WRAP PROGRAM 11  broker-dealers to the extent used under the Program. Thus, there may be a financial incentive for SPA to invest client assets under the Program in such investments over other investments, or to place client orders with such Custodians and broker-dealers over other Custodians and broker-dealers, for which Sentinel Securities, SPA or another SPA affiliate would not receive such services and fees. SPA may recommend third parties for custody or brokerage services under the Program. SPA (or its affiliates) may receive direct or indirect benefits through participation in such Program, such as, among other things, access to research related products and tools and shareholder servicing payments. In addition, as discussed above, a person may receive a referral fee for recommending the Program. The amount of that referral fee may be more than what the person would receive if the person recommended another wrap fee program or the referred person paid separately for investment advisory services, brokerage, and other services, and, therefore, that person may have a financial incentive to recommend the Program over other programs or services. Potential conflicts of interest may arise regarding the allocation of investment opportunities among clients advised by SPA. SPA will seek to allocate investment opportunities believed appropriate for more than one client on a fair and equitable basis. There can be no assurance that any particular investment opportunity will be allocated in any particular manner. M. Risk of Loss The client understands, acknowledges and agrees that no assurance has been or can be given to the client that the client will achieve his or her investment objectives by accepting or implementing in whole or in part any investment strategy and/or allocation or any specific recommendation by SPA to purchase or sell any security or other investment or participate in the Program. Securities markets fluctuate substantially over time. All investments in securities include a risk of loss of money invested (principal) and any unrealized profits (i.e., profits in the account that have not been liquidated, sometimes called “paper profits”). SPA cannot guarantee any level of performance or that clients will not experience a loss of account assets. SPA does not represent, warrant or imply that the services or methods of analysis used by SPA can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to major market corrections or crashes. No guarantees can be offered that clients’ goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by SPA will provide a better return than other investment strategies. The managers of the mutual funds and ETFs that SPA selects to participate in the Program may employ the same or substantially similar investment strategies, and may hold similar portfolios of investments, in other investment products or programs that they manage, such as managed account programs. Such other products or programs may be available through SPA or elsewhere. The costs and the services relating to the other products or programs in which these strategies are offered may differ. Varied fluctuations in the price of investments are a normal characteristic of securities markets due to a variety of influences. Managed account programs should be considered a long-term investment and thus long-term performance, and performance consistency are the major goals. SPA WRAP PROGRAM 12  There is no assurance that the no-load mutual funds, select load-waived mutual funds and ETFs will perform in any particular manner. Past performance of any mutual fund, ETF or asset class is no guarantee of future performance. Clients should carefully read the prospectus of each mutual fund and ETF before they invest. No guarantees can be offered that client’s goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by SPA will provide a better return than other investment strategies. The client has been informed, understands and acknowledges that unless stated otherwise in a supplemental disclosure document related to a specific investment or program, the investments in the client’s Program account are not insured by the Federal Deposit Insurance Corporation (“FDIC”), are not deposits with or the obligation of or guaranteed by SPA or the Custodian or any of their affiliates, are subject to investment risk, including possible loss of principal invested, and that past performance is no guarantee of future results. V. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Minimum Account Size SPA requires an account minimum of $25,000 for participation in the Program. However, SPA, in its sole discretion, may reduce the account minimum based upon certain criteria including, among others, anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts and account composition. Types of Clients SPA provides portfolio management services to individuals, pensions and profit-sharing plans, trusts, estates, charitable organizations, corporations and other business entities. Account Opening Once suitability for the client is established, the investor opens an account by signing the Program’s investment management agreement (the “Client Agreement”) with SPA and a new account agreement with Sentinel Securities. Transactions, Confirmations and Account Statements The Custodian will provide the client with the following reports of relevant activity in the account: (i) trade confirmations reflecting all transactions effected with or through the Custodian (other than cash sweep transactions) and (ii) account statements not less than quarterly itemizing all transactions in cash and securities and all deposits and withdrawals of principal and income and listing securities in custody held in the account. Performance Reports Clients will receive investment performance reports from SPA on a quarterly basis in the form of mail, electronic delivery or a client meeting based upon the client’s request. VI. PORTFOLIO MANAGER SELECTION AND EVALUATION A. About Sentinel Pension Advisors, LLC. Sentinel Pension Advisors “SPA” is an SEC-registered investment adviser located at 100 Quannapowitt Parkway, Suite 300, Wakefield, MA 01880. SPA provides investment advisory services to individual and institutional clients such as corporate, trust, estate and retirement accounts as well as pension and profit-sharing plans outside of this Program. SPA WRAP PROGRAM 13  SPA’s investment committee is responsible for identifying and selecting the no-load mutual funds, select load-waived mutual funds and ETFs offered under the Program based on each client’s individual goals, investment objectives and investment restrictions as presented by the client to SPA. SPA is a subsidiary of Focus Operating, LLC, which is a subsidiary of Focus Financial Partners, LLC. The managers of the mutual funds and ETFs that SPA selects to participate in the Program may employ the same or substantially similar investment strategies, and may hold similar portfolios of investments, in other investment products or programs that they manage, such as managed account programs. Such other products or programs may be available through SPA or elsewhere. The costs and the services relating to the other products or programs in which these strategies are offered may differ. B. Portfolio Performance Review Portfolio performance is reviewed on an ongoing basis by SPA. SPA has retained the services of an independent third party, to prepare model portfolio and individual client performance reports at no additional fee to Program Clients. This Independent Third Party incorporates a daily, time-weighted performance measurement with multi-period returns calculated in compliance with CFA GIPS standards. Performance dimensions include style, class, asset type, and sector variables. All Program Clients are encouraged to discuss their investment objectives, needs and goals with SPA and to keep SPA informed of any changes. All Program clients are encouraged to meet, at least annually, with SPA to comprehensively review their investment objectives. The SPA Investment Committee manages the SPA Wrap Fee Program based on the stated objectives of the program guidelines. C. SPA’s Investment Selection Process The SPA investment committee follows a disciplined research and evaluation process to determine appropriate investments for each portfolio based on its target allocation. Listed below are examples of selection criteria utilized in SPA’s proprietary screening process. One or more of these will be used in SPA’s analysis: Quantitative Factors: 1. Returns vs. peer funds: 1, 3, and 5 year total returns 2. Consistency of returns 3. Risk-adjusted measures of return: Sharpe Ration, Information Ratio, Up/Down Capture, Alpha, Batting Average 4. Volatility vs. Peers: Standard deviation of return 5. Expense ratio analysis Qualitative Factors: 1. Management tenure and personnel 2. Investment process / decision making procedures 3. Style consistency 4. Portfolio or sector concentration 5. Fiduciary matters 6. Information availability Performance of each portfolio and the underlying strategies are regularly monitored by SPA’s investment committee to determine if the investments continue to meet SPA’s strict criteria. The committee also monitors market conditions and, if needed, rebalances the portfolios to return them to their target asset allocation. VII. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The portfolio managers receive information regarding investment objective and risk SPA WRAP PROGRAM 14  tolerance parameters from the client. SPA does not disclose any nonpublic personal information about its customers or former customers to any nonaffiliated third parties, except as permitted by law. SPA may share some information with its service providers, such as transfer agents, custodians, broker-dealers, accountants, and lawyers. SPA restricts internal access to nonpublic personal information about the Client to those associated persons of the Firm who need access to that information in order to provide services to the Client. SPA Investment Advisor Representatives meet with clients annually or at the frequency agreed to in the Client Agreement. Any changes in client investment objectives and risk tolerance parameters will be promptly transmitted to the portfolio managers. SPA will update this Brochure when there are any material changes in this program or the services provided, but in any event, SPA will review this brochure no less frequently than annually and make any necessary changes at that time. VIII. CLIENT CONTACT WITH PORTFOLIO MANAGERS The Program is managed in one of two ways: a financial advisor managed portfolio or a portfolio managed by a third manager. There are no restrictions placed on a client’s ability to contact and consult with their financial advisor, or members of the Investment Committee. IX. ADDITIONAL INFORMATION A. Disciplinary information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business or the integrity of our management. B. Other Industry Activities and Affiliations The principal executive officers of SPA are also pension consultants and/or officers of Sentinel Benefits Group, Inc. (‘’SBG’’), a third-party administration firm for pension plans. SBG is affiliated with SPA through common ownership and control. SPA clients can choose to use the pension administration services of SBG. Fees for SBG’s pension administration services are in addition to SPA advisory fees. No SPA client is obligated to use SBG for pension administration services. SBG may recommend the advisory services of SPA to its clients. There is no referral fee arrangement between SPA and SBG. The principal executive officers of SPA are also agents, and/or officers of Sentinel Insurance Agency. These individuals are also independent agents for various insurance companies. Therefore, these individuals will be able to purchase insurance products for any client in need of such services. These individuals will be able to receive separate, yet typical compensation for the purchase of insurance products. SPA, its Advisory Representatives and related persons have a conflict of interest to recommend insurance products to clients since commissions may be earned in addition to fees for advisory services. Clients are not obligated to purchase insurance products through SPA or its Advisory Representatives. Clients are under no obligation to purchase or sell securities through SPA agents. However, if a client chooses to implement the recommendations, commissions may be earned by SPA agents (i.e. Sentinel Securities or Sentinel Insurance Agency) in addition to any fees paid for advisory services. Commissions may be higher or lower at Sentinel Securities than at other broker-dealers. SPA WRAP PROGRAM 15  SPA Advisory Representatives may have a conflict of interest in having clients purchase securities and/or insurance related products through Sentinel Securities, in that the higher their production with Sentinel Securities the greater potential for obtaining a higher payout on commissions earned. Further, Advisory Representatives may be restricted to only offering those products and services that have been reviewed and approved for offering to the public through Sentinel Securities. The principal executive officers and other related “employees” of SPA are officers, managers, and/or registered representatives of Sentinel Securities, a registered broker-dealer and FINRA member. Sentinel Securities is affiliated with SPA through common ownership and control. These individuals will be able to effect separate securities transactions for advisory clients and Sentinel Securities may receive separate and customary compensation for this activity and may pay a portion of the compensation to these individuals. In some circumstances, Sentinel Securities may receive customary compensation from mutual fund companies and/or variable annuity companies, including 12b-1 fees, for performing certain administrative and/or shareholder servicing related tasks associated with a SPA client’s investments in such securities. Sentinel Securities’ securities business is primarily limited to mutual fund shares and variable insurance contracts. SPA is a subsidiary of Focus Operating, LLC, which is a subsidiary of Focus Financial Partners, LLC (“Focus”). Focus also controls other registered investment advisors, broker- dealers, pension consultants, insurance firms, and other financial services firms (the “Focus Affiliates”).The Focus Affiliates may provide, among other services, wealth management, benefit and other investment consulting services that may serve individuals, families, employers, and institutions. Some Focus Affiliates also manage or advise limited partnerships, private funds, or limited liability companies as disclosed on their respective Forms ADV Schedule D. Focus Affiliates with whom SPA has a material business relationship are listed in SPA’s Form ADV Part 1 Schedule D, and below. Additional information about the Focus Affiliates is available at www.focusfinancialpartners.com. As noted in response to Item 4, SPA is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, SPA is a wholly-owned indirect subsidiary of Focus LLC. SPA may from time to time recommend services of other Focus affiliates to our clients. Please note that no financial incentives or compensation of any kind are exchanged between SPA and Focus affiliates with regard to mutual clients. Focus Financial Partners, Inc. is the sole managing member of Focus LLC. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”) and investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”). As a result, SPA is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles. SPA may recommend investments managed or advised by Focus Affiliates. Please note that no financial incentives or compensation of any kind are exchanged between SPA and Focus affiliates with regard to any recommended investments managed or advised by Focus Affiliates. SPA and Focus Partners Wealth, LLC (“FPW”) are both advisory firms owned by Focus. SPA and FPW have an agreement in place whereby FPW serves as a subadvisor to SPA for certain client retirement plans. SPA and the client enter an advisory agreement that specifies the discretionary and/or non-discretionary advisory services and duties to be delegated to FPW. Generally, FPW is responsible for investment recommendations and creating and maintaining model portfolios, individual fund choices, and asset allocation targets. SPA is generally responsible for fiduciary governance, participant services, and portfolio SPA WRAP PROGRAM 16  administration, including trading, rebalancing, and fiduciary and performance reporting. FPW, at its discretion, may participate in Sentinel’s investment meetings with clients. As the advisor to the client, SPA collects its quarterly advisory fee and remits 50% of such fee to FPW for its services. SPA and Mosaic Family Wealth Partners, LLC (“Mosaic”) are both advisory firms owned by Focus. SPA and Mosaic have an agreement in place whereby Mosaic serves as a subadvisor to SPA for certain client retirement plans. SPA and the client enter an advisory agreement that specifies the discretionary and/or non- discretionary advisory services and duties to be delegated to Mosaic. Generally, Mosaic is responsible for investment recommendations and creating and maintaining model portfolios, individual fund choices, and asset allocation targets. SPA is generally responsible for fiduciary governance, participant services, and portfolio administration, including trading, rebalancing, and fiduciary and performance reporting. Mosaic at its discretion, may participate in Sentinel’s investment meetings with clients. As the advisor to the client, SPA collects its quarterly advisory fee and 50% of such fee to Mosaic for its services. To the extent SPA employees who, in their registered representative capacity with Sentinel Securities, serve as broker of record for a qualified retirement plan (“Plans”), the registered representatives may recommend the purchase of a group annuity policy as the funding vehicle for the Plan through its affiliated insurance agency, Sentinel Insurance. In no event will such Plan also be a client of SPA. If a registered representative refers a Plan whose funding vehicle is a group annuity to Sentinel Insurance, the registered representative may be paid a portion of commissions received by Sentinel Insurance. SPA provides certain advisory services with respect to the accounts of Participants of Plans in connection with the investment advisory services that SPA provides to the plan sponsors of such Plans. In some instances, a participant may elect to transfer his/her account (e.g., an IRA) out of the Plan to be managed separately by SPA. SPA may recommend the use of Sentinel Securities (and other brokers unaffiliated with SPA), who provide brokerage services, to such participant in such event. Under these circumstances, the participant may pay greater fees to SPA and commissions to the selected broker-dealer with respect to his/her account for the same services that the participant would have received had his/her account remained in the Plan. Thus, there may be a financial incentive for SPA (and/or its affiliated broker-dealer, Sentinel Securities) to encourage participants to transfer their accounts out of their respective Plans to be managed separately by SPA. Advice offered by SPA’s Advisory Representatives may involve investment in mutual funds. Mutual funds may carry loads (i.e. sales charges) that may be up-front or on a contingent deferred basis, or can be no-loads with no initial or contingent deferred sales charges. Clients are advised that Advisory Representatives are registered representatives of Sentinel Securities, a registered broker-dealer, member of the Financial Industry Regulatory Authority (“FINRA”) and SIPC. Therefore, Advisory Representatives have a conflict of interest in recommending mutual funds that carry a load since such mutual funds will pay Advisory Representatives a commission should the purchase be made through Advisory Representatives. A conflict of interest may exist between the interests of SPA and/or its Advisory Representatives and the interests of the client in that SPA and Advisory Representatives offer financial planning and investment advisory services for a fee and also offer various securities products for which they may be paid a commission. The securities products available through SPA may be limited to certain products that have been reviewed and made available for offering through the broker/dealer with which Advisory Representatives may be registered representatives. Lower fees for comparable services may be available from other sources. Material conflicts of interest disclosed to the client in writing via this Form ADV, Part 2 could cause SPA or its Advisory Representatives to not render unbiased and objective advice. SPA WRAP PROGRAM 17  Clients are advised that the investment recommendations, and advice offered by SPA, are not legal recommendations or advice, nor does it constitute accounting advice. Clients should coordinate and discuss the impact of financial advice with their attorney and/or accountant. Clients are advised that it is necessary to inform SPA promptly with respect to any changes in the client’s financial situation and investment goals and objectives. Failure to notify SPA of any such changes could result in investment recommendations being made that are based upon inaccurate information, thus will not meet the needs of the client. The level of experience of Advisory Representatives will vary. Additionally, the fees charged by various Advisory Representatives will not exceed the fee schedules disclosed herein but may vary. Therefore, clients receiving similar services may pay higher or lower fees than another client depending on their Advisory Representative. A higher fee is not necessarily commensurate with the experience of the Advisory Representative. Advisory Representatives who are Registered Representatives of Sentinel Securities may receive trail commissions (i.e. 12b-1 fees) for a period of time. Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees may be initially paid to Sentinel Securities and a portion passed to the Advisory Representatives. The receipt of such fees could represent an incentive for Advisory Representatives to recommend funds with12b-1 fees over funds that have no fees or lower fees. As a result, there is a potential conflict of interest. Periodically Focus Financial Partners, LLC (“Focus”), our parent company, holds partnership meetings and other industry and best-practices conferences, which typically include Focus firm and external attendees. These meetings provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms, including Sentinel Pension Advisors, LLC., and facilitate access to our advisors and employees to discuss ideas, products and services. This could be deemed a conflict: the marketing and education activities conducted, and the access granted, at such meetings and conferences may lead advisors to focus on those conference sponsors in the course of their duties. Focus attempts to mitigate any such conflict by having the fees only go towards defraying the cost of such meeting or future meetings and not as revenue for itself or any affiliate. Conference sponsorship fees are not dependent on assets placed with any specific provider, or the revenue generated by asset placement. SPA also holds meetings and other industry and best-practices conferences, which typically include firm and external attendees. These meetings provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to SPA and other attendees and facilitate access to our advisors and employees to discuss ideas, products and services. This could be deemed a conflict: the marketing and education activities conducted, and the access granted, at such meetings and conferences may lead advisors to focus on those conference sponsors in the course of their duties. SPA attempts to mitigate any such conflict by having the fees only go towards defraying the cost of such meeting or future meetings and not as revenue for itself or any affiliate. Conference sponsorship fees are not dependent on assets placed with any specific provider, or the revenue generated by asset placement. C. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Code of Ethics SPA has in place a Code of Ethics that provides for SPA and its Advisor Representatives to exercise its fiduciary duty to clients to act in the best interest of the client and always place the client’s interests first and foremost. SPA takes its compliance and regulatory obligations SPA WRAP PROGRAM 18  seriously and requires all staff to comply with such rules and regulations as well as SPA’ policies and procedures. The Code of Ethics (the “Code”) has been adopted by SPA and is designed to comply with Rule 204A-1 under the Investment Advisors Act of 1940, as amended (“Advisors Act”).The Code establishes rules of conduct for all employees of SPA and is designed to, among other things; govern personal securities trading activities in the accounts of employees. The Code is based upon the principle that SPA and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code is designed to ensure that the high ethical standards long maintained by SPA continue to be applied. The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. The excellent name and reputation of our firm continues to be a direct reflection of the conduct of each employee. Pursuant to Section 206 of the Advisors Act, both SPA and its employees are prohibited from engaging in fraudulent, deceptive or manipulative conduct. Compliance with this section involves more than acting with honesty and good faith alone. In meeting its fiduciary responsibilities to its clients, SPA expects every employee to demonstrate the highest standards of ethical conduct for continued employment with SPA. Strict compliance with the provisions of the Code shall be considered a basic condition of employment with SPA. SPA reputation for fair and honest dealing with its clients has taken considerable time to build. This standing could be seriously damaged as the result of even a single securities transaction being considered questionable in light of the fiduciary duty owed to our clients. SPA employees are urged to seek the advice of the Chief Compliance Officer for any questions about the Code or the application of the Code to their individual circumstances. A material breach of the provisions of the Code by an employee may constitute grounds for disciplinary action, including termination of employment with SPA. Privacy Policy SPA recognizes and respects the privacy of each of its customers and their expectations for confidentiality. The protection of customer information is of fundamental importance in SPA’s operation and SPA takes its responsibility to protect nonpublic personal information seriously. SPA collects, retains and uses information that assists SPA in providing the best service possible. This information comes from the following sources: • Account applications and other required forms • Written, oral, electronic or telephonic communications and • Account and transaction histories with us, our affiliates, or others SPA does not disclose any nonpublic personal information about SPA’s customers or former customers to anyone, except as permitted by law. SPA restricts access to nonpublic personal information about you to those employees, affiliates, and service SPA WRAP PROGRAM 19  providers who need to know that information to provide SPA products or services to you. SPA requires that these entities limit the use of the information provided to the purposes for which it was disclosed and as permitted by law. SPA maintains physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. Participation or Interest in Client Transactions and Personal Trading As SPA and its Advisory Representatives are aware of recommendations to clients, a conflict of interest exists where there is a possibility that SPA or its Advisory Representatives may take advantage of this knowledge and engage in transactions prior to clients being given recommendations. To address this conflict, it is the express policy of SPA that no person employed by SPA may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, and therefore, preventing such employees from benefiting from transactions placed on behalf of advisory accounts. Thus, Sentinel and its related persons do not recommend securities to clients, or buy or sell securities for client accounts, at or about the same time that Sentinel or a related person buys or sells the same securities for its own (or the related person’s own) account. Notwithstanding the restriction on engaging in transactions prior to clients, SPA, or individuals associated with SPA, may buy or sell securities identical to those recommended to customers for their personal accounts. It is the policy of SPA that such transactions cannot be made to the detriment of the client. SPA’s Compliance Department monitors the trading of SPA employees and Advisory Representatives and has in place processes to address violations of this policy. Additionally, SPA or its related persons may have a material financial interest in securities which may also be recommended to a client. A conflict of interest exists in these situations whereby client transactions in such entities could have a financial benefit to SPA or its related persons. To address this conflict, in addition to the requirement to always act in the clients’ best interest, SPA has established the following restrictions: 1. A director, officer or employee of SPA shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No person of SPA shall prefer his or her own interest to that of the advisory client. 2. SPA maintains a list of all securities holdings for itself, and anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of SPA. 3. All clients are fully informed that certain individuals may receive separate compensation when effecting transactions during the implementation process. 4. SPA emphasizes the unrestricted right of the client to decline to implement any advice rendered, except in situations where SPA is granted discretionary authority of the client’s account. SPA WRAP PROGRAM 20  5. SPA emphasizes the unrestricted right of the client to select and choose any broker or dealer, and/or insurance company (s)he wishes. 6. SPA requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 7. Any individual not in observance of the above may be subject to termination. D. Review of Accounts Account assets for Investment Advisory clients are supervised continuously and formally reviewed at least annually by the Advisory Representative assigned to the account. The review process will include, but is not limited to, comparing the current asset allocation to the asset allocation models, or the recommended asset allocation and evaluating the need for rebalancing. Additional account reviews may be triggered by any of the following events: a specific client request, deposit or withdrawal of client funds, or a change in the clients. stated goals or objectives. At a minimum, quarterly reports will be furnished by the custodian. SPA does not provide monthly or quarterly statements to clients. Account activity in any given month will generate an account statement for that month. E. Client Referrals and Other Compensation If a client is introduced to SPA by either an unaffiliated or an affiliated promoter, SPA will pay that promoter a referral fee only if an agreement is in place that is in accordance with the requirements of Rule 206(4)-3 of the Investment Advisors Act of 1940, as amended (the “Advisors Act”), and any applicable state securities law requirements. SPA has entered into promoter relationships with other investment advisers, broker-dealers, and financial planning firms whereby the promoter will refer clients to SPA which clients may be a candidate for the investment advisory services offered by SPA. SPA shares advisory fees with promoters on a negotiated basis for soliciting business for SPA. Compensation to promoters will be an agreed upon percentage of SPA’s advisory fee. This fee is paid in arrears and in most instances continues to be paid to promoters for as long as SPA receives fees on the account. Any such referral fee shall be paid solely from the Program fee paid to SPA and shall not result in any additional charge to the client. If the client is introduced to SPA by an unaffiliated promoter, the promoter shall provide the client with a copy of Form ADV Part 2, the Wrap Fee Program brochure, Form CRS and a copy of the disclosure statement between SPA and the promoter containing the terms and conditions of the solicitation arrangement, including compensation. Any affiliated promoter of SPA shall disclose the nature of his/her relationship to prospective clients at the time of the solicitation and will provide all prospective clients with a copy of the Form ADV Part 2, Wrap Fee Program brochure, and the Form CRS at the time of the solicitation. SPA’s principal executive officers and advisor representatives, from time to time, receive incentive awards or non-cash compensation for the recommendation/ introduction of investment products. While these individuals endeavor at all times to put the interest of the clients first as part of SPA’s fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. All non-cash compensation must be disclosed to and, in certain SPA WRAP PROGRAM 21  instances, approved by the SPA Compliance Department. The SPA Compliance Department reviews and tracks all non-cash compensation or incentive awards provided to any SPA investment advisory representative from an outside firm to ensure compliance with all applicable rules and regulations. Certain mutual funds and variable annuities in which you are invested may pay marketing fees, service fees, including shareholder service fees, 12b-1 fees, to SPA or Sentinel Securities, LLC our affiliated broker/dealer for marketing assistance or the performance of certain administrative tasks associated with making an investment in such fund or annuity. Any such fees received by us will not be credited against the fees otherwise payable by individual clients to us. Our employees or associated persons on occasion are invited to attend seminars and meetings with the costs associated with such meetings borne by a sponsoring brokerage firm or other party extending the invitation. SPA will recommend the Sentinel Securities, LLC, Charles Schwab & Co., Inc. (Schwab), or Fidelity Brokerage Services, LLC. (“Fidelity”) FINRA registered broker dealers, to clients in need of brokerage services. While there is no direct linkage between the investment advice given and implementation of securities transactions through these arrangements, economic benefits are received which would not be received if SPA did not give investment advice to clients. These benefits include: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk serving participants exclusively; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; ability to have investment advisory fees deducted directly from client account; access, for a fee, to an electronic communication network for client order entry and account information; receipt of compliance publications; and access to mutual funds which generally require significantly higher minimum initial investments or are generally available only to institutional investors. The benefits received through participation in the SPA, Schwab or Fidelity programs may or may not depend upon the amount of transactions directed to, or amount of assets custodied. In addition, certain employees of SPA hold securities licenses at and are deemed “registered representatives” of Sentinel Securities. From time to time, such employees may act in their “registered representative” capacity as “broker of record” for a Plan. Pursuant to such arrangement, the registered representative will receive commission compensation from the Plan. In all cases, whether acting through SPA or as a registered representative of Sentinel Securities, the employee (who is a registered representative) does not have discretion over any client’s account. Financial Information SPA has not attached a balance sheet for its most recent fiscal year because it does not have custody of client assets or require prepayment of more than $1,200 in fees per client and six or more months in advance. SPA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. X. REQUIREMENTS FOR STATE-REGISTERED ADVISORS Not Applicable SPA WRAP PROGRAM 22  SPA WRAP PROGRAM 23