Signal Ridge Capital Partners, LLC

Item 1: Cover Page Form ADV Part 2A Investment Adviser Brochure 434 Old Connecticut Path, Suite 3A Framingham, MA 01701 jsmitka@signalridgecp.com (617) 607-3222 www.signalridgecp.com September 2026 This brochure provides information about the qualifications and business practices of Signal Ridge Capital Partners, LLC. If you have any questions about the contents of this brochure, please contact John F. Smitka, Jr., Chief Compliance Officer. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration as an investment adviser does not imply any level of skill or training. Additional information about Signal Ridge Capital Partners, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number. Signal Ridge Capital Partners, LLC’s CRD Number is 167576.  Item 2: Summary of Material Changes Annual Update – Material Changes The material changes in this brochure from the last annual updating amendment of Signal Ridge Capital Partners, LLC on March 26, 2026, are described below. Material changes relate to Signal Ridge Capital Partners, LLC’s policies, practices, or conflicts of interests. • Signal Ridge Capital Partners, LLC has removed Matthew Butler Scales. (Item 12) • Signal Ridge Capital Partners, LLC has removed Charles Schwab as custodian. (Item 12) Full Brochure Available Copies of Signal Ridge’s Brochure and Supplement may be requested at any time, without charge by contacting John F. Smitka, Jr., Chief Compliance Officer, at (617) 607-3222 or jsmitka@signalridgecp.com. 2 Form ADV Part 2A  Item 3: Table of Contents Table of Contents Item 1: Cover Page ______________________________________________________________________________ 1 Item 2: Summary of Material Changes _______________________________________________________________ 2 Item 3: Table of Contents _________________________________________________________________________ 3 Item 4: Advisory Business ________________________________________________________________________ 5 Financial Planning and Consulting Services _____________________________________________ 5 Investment Management Services ____________________________________________________ 5 Sub-Advisory Relationships __________________________________________________________ 6 Tailored Services __________________________________________________________________ 6 Assets Under Management _________________________________________________________ 7 Item 5: Fees and Compensation____________________________________________________________________ 7 Financial Planning and Consulting Fees ________________________________________________ 7 Investment Management Fee _______________________________________________________ 7 Sub-Advisory Fee _________________________________________________________________ 8 Other Expenses ___________________________________________________________________ 8 Sponsor / Manager of Signal Ridge Capital Partners Wrap Program _________________________ 8 Fees for Management During Partial Quarters of Service __________________________________ 8 Item 6: Performance-Based Fees and Side-by-Side Management _________________________________________ 8 Item 7: Types of Clients __________________________________________________________________________ 8 Minimum Account Requirements _____________________________________________________ 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ______________________________________ 9 Methods of Analysis _______________________________________________________________ 9 Investment Strategies and Implementation ____________________________________________ 10 Item 9: Disciplinary Information __________________________________________________________________ 15 Item 10: Other Financial Industry Activities and Affiliations ____________________________________________ 15 Financial Industry Activities ________________________________________________________ 15 Affiliations – Other Investment Related Activities _______________________________________ 15 Affiliations – Lawyer ______________________________________________________________ 15 Affiliations – Other Investment Advisers ______________________________________________ 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading _________________ 15 Code of Ethics ___________________________________________________________________ 15 Participation or Interest in Client Transactions – Personal Securities Transactions _____________ 16 3 Form ADV Part 2A  Item 12: Brokerage Practices _____________________________________________________________________ 16 Item 13: Review of Accounts _____________________________________________________________________ 18 Item 14: Client Referrals and Other Compensation ___________________________________________________ 18 Item 15: Custody _______________________________________________________________________________ 18 SEC “Custody” ___________________________________________________________________ 19 Item 16: Investment Discretion ___________________________________________________________________ 19 Item 17: Voting Client Securities __________________________________________________________________ 20 Item 18: Financial Information____________________________________________________________________ 20 Item 19: Additional Information __________________________________________________________________ 20 Privacy ________________________________________________________________________ 20 Business Continuity Plan (BCP) ______________________________________________________ 20 4 Form ADV Part 2A  Item 4: Advisory Business Signal Ridge Capital Partners, LLC (“Signal Ridge” or the “Firm”) provides financial planning, consulting, and investment management services to its clients. Signal Ridge was formed as a Massachusetts limited liability company. Financial Planning and Consulting Services Signal Ridge provides its clients with a broad range of financial planning and consulting services. These services may include financial and investment advice in connection with retirement, educational expenses, estate planning, business planning, and cash flow needs of the client. The client is under no obligation to act upon any of the recommendations made by Signal Ridge under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Signal Ridge itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Signal Ridge recommendations. Signal Ridge does not provide tax or accounting advice. Upon a client’s request, the Firm may recommend one or more firms. While the Firm believes that such firms are competent and trustworthy, it does not guarantee the quality of the service they provide. The Firm receives no compensation for such referrals, though such firms may refer clients to us. Investment Management Services Clients can engage Signal Ridge to manage all or a portion of their assets on a discretionary or non- discretionary basis. In discretionary accounts, the Firm primarily allocates clients’ custodial assets among the following securities: • Mutual Funds • Exchange Traded Funds (ETFs) • Exchange Traded Notes (ETNs) • Leveraged Exchange Traded Funds • Leveraged Exchange Traded Notes • Domestic Equities • Foreign Equities • Corporate Bonds • Commercial Paper • Certificates of Deposit • Municipal Bonds • U.S. Treasuries • Options 5 Form ADV Part 2A  • Futures • Real Estate Investment Trusts (REITs) • Commodities • Preferred Stocks Because the above investments involve varying degrees of risk, they will only be utilized or recommended when consistent with a client's stated investment goals, risk tolerance, liquidity needs, and tax circumstances. Importantly, we consider the riskiness of any single investment within the broader context of a client’s overall portfolio in addition to the risk characteristics of any individual security. Under certain client circumstances, Signal Ridge may use leveraged ETFs and/or ETNs. The use of leveraged ETFs and ETNs and their suitability for long-term investors should be viewed within the context of a broader portfolio. The appropriate use of these securities can allow a portfolio to perform more consistently - i.e. a higher Sharpe ratio, or ratio of annualized excess return divided by annualized standard deviation - over time than a portfolio that does not use leveraged securities and seeks greater returns through concentrating risk in higher volatility asset classes. The use of leveraged ETFs and ETNs will only be used only with those clients that have a risk tolerance that is speculative and seek higher returns but want to avoid concentrating their portfolio risk. As part of Signal Ridge’s investment management services, and depending on a client’s individual needs, Signal Ridge has the ability to create custom portfolios or offer clients a range of model portfolios that have been internally developed to align with the risk tolerances of individual clients. Upon assessing a client's individual circumstances and using the appropriate model portfolio as a starting point, Signal Ridge can customize a client's portfolio based on additional factors. These factors may include, but are not limited to, tax circumstances, liquidity needs, portfolio size, or personal interests such as supporting renewable energy companies. After determining the risk profile and other unique client circumstances, Signal Ridge will make recommendations on additional portfolio considerations and recommend the inclusion or exclusion of certain customized strategies. Once Signal Ridge constructs an investment portfolio for a client, Signal Ridge monitors each client’s investment strategy and performance on an ongoing basis and will rebalance the portfolio as appropriate. If client financial circumstances and/or investment objectives change they are expected to notify Signal Ridge immediately to ensure the ongoing fit of their portfolio with their risk profile. For non-discretionary accounts, the client has responsibility for all investment decisions across all capital market asset classes (for example, individual stocks and bonds, mutual funds, ETFs and cash and cash equivalents.) The Firm can provide advice on asset allocation decisions and the subsequent buying and selling decisions to non-discretionary clients. Sub-Advisory Relationships Signal Ridge may provide services to unaffiliated registered investment advisers on a sub-advisory basis. Tailored Services Signal Ridge tailors its advisory services to the individual needs of clients. Signal Ridge consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon, and other factors that may impact the clients’ investment needs. Signal Ridge ensures that clients’ investments are suitable for their investment needs, goals, objectives, and risk tolerance. 6 Form ADV Part 2A  Clients are advised to promptly notify Signal Ridge if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Signal Ridge management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible investments) if, in Signal Ridge’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or constrain Signal Ridge’s ability to efficiently manage the portfolio. In performing its services, Signal Ridge relies on any information it received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and does not independently verify such information. Assets Under Management As of December 31, 2025, Signal Ridge manages $113,558,122 in assets under management; all of which is currently managed on a discretionary basis. Item 5: Fees and Compensation Signal Ridge generally offers its services on a percentage fee basis based upon assets under management. Alternative fee arrangements may include an hourly rate and/or fixed fees. Prior to engaging Signal Ridge, the client is required to enter into a written agreement (“Agreement”) with Signal Ridge setting forth the terms and conditions of the engagement. Signal Ridge collects financial planning and consulting fees in arrears at the delivery of the financial plan or completion of the agreed upon services. Financial Planning and Consulting Fees Signal Ridge may charge a fixed fee and/or hourly fee for financial planning and consulting services. These fees are negotiable based on the scope of the work, but generally range from $1,000 to $15,000 on a fixed fee basis and/or $350 on an hourly rate basis. If the client engages Signal Ridge for additional investment management services, Signal Ridge may offset a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. Investment Management Fee Signal Ridge provides investment management services for an annual fee based upon a percentage of the market value of the assets being managed by Signal Ridge. Signal Ridge annual fee is prorated and charged quarterly, in advance or in arrears, based upon the market value of the assets being managed by Signal Ridge on the last day of the previous or current quarter. The basis for the annual fee is as follows: Household Assets First $2 Million Next $3 Million Next $5 Million Above $10 Million Annual Fee 1.00% 0.90% 0.80% 0.70% In certain circumstances, fees, account minimums and payment terms are negotiable, in Signal Ridge’s sole discretion, depending on client’s unique circumstances. These circumstances may include, but are not limited to, the size of the aggregate related party portfolio, level of service, family holdings, low- 7 Form ADV Part 2A  cost basis securities, or certain passively advised investments and pre-existing relationships with clients. Certain clients may pay more or less than others depending on the amount of assets, type of portfolio, the time involved, the degree of responsibility assumed, complexity of the engagement, special skills needed to solve problems, and the application of experience and knowledge of the client’s situation. Lower fees for comparable services may be available from other sources. Sub-Advisory Fee The annual compensation for any of Signal Ridge’s sub-advised relationships would be paid by the investment adviser engaging the Firm’s services. Other Expenses In addition to Signal Ridge’s annual fee, clients may incur certain charges imposed by third-party service providers to client’s account, such as custodial fees, brokerage commission and transaction fees (except for accounts of clients in the Wrap Program), odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual Funds and ETFs incur fund-level costs (e.g., fund management fees, administrative expenses) paid directly by the fund, and sales charges which are paid by the investor. All such charges are disclosed in the funds’ prospectus. Sponsor / Manager of Signal Ridge Capital Partners Wrap Program Signal Ridge sponsors and manages the Signal Ridge Capital Partners Wrap Fee Program (the “Wrap Program”). Under the Wrap Program, the investment management fee paid by a client covers both Signal Ridge’s advisory services and brokerage expenses associated with securities transactions in the client’s managed account. Participants in the Wrap Program may pay a higher aggregate fee than if investment management and brokerage services are purchased separately. A complete description of the Wrap Program’s terms and conditions (including fees) is contained in the Wrap Program’s brochure. Fees for Management During Partial Quarters of Service For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement between Signal Ridge and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. Signal Ridge fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. Item 6: Performance-Based Fees and Side-by-Side Management Signal Ridge does not charge performance-based fees. Performance-based fees are those based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients Signal Ridge generally provides its services to individuals, high net worth individuals, business entities, trusts, estates, charitable organizations, and qualified plans. 8 Form ADV Part 2A  Minimum Account Requirements Signal Ridge requires a minimum account size of $1,000,000 for investment management clients, although this may be negotiable under certain circumstances. Signal Ridge may group certain related client accounts for the purpose of achieving the minimum account size. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Macroeconomic Analysis - Macroeconomics is the study of the behavior of the economy as a whole and uses various economic indicators that tell us about the overall health of the economy. Macroeconomic analysis can help consumers, firms, and governments make better decisions: Consumers want to know how easy it will be to find work, how much it will cost to buy goods and services in the market, or how much it may cost to borrow money. Businesses use macroeconomic analysis to determine whether expanding production will be welcomed by the market. Governments and central banks turn to macroeconomics when determining budgets, creating taxes, deciding on interest rates, and making policy decisions. Within an investment portfolio, understanding how different asset classes respond to changes in the macroeconomic environment can help investment decision makers make more informed decisions with the goal of improving the overall effectiveness of the portfolio. Fundamental Analysis - Fundamental analysis involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and skill of the company's management, and the outlook for the company's industry. The resulting data is used to measure the true value of the company's equity and debt issuance compared to current market prices. The risk of fundamental analysis is that information obtained or conclusions drawn are incorrect and the analysis will not provide an accurate estimate of the company’s performance and outlook which in turn, can affect the value of the company’s stock and their creditworthiness, or ability to repay its debt. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Quantitative Analysis - Quantitative analysis is a technique that seeks to understand asset price behavior by using mathematical and statistical modeling, measurement, and research. Quantitative analysis aims to represent a given reality in terms of a numerical value. Quantitative analysis is employed for several reasons, including measurement, performance evaluation or valuation of a financial instrument, and predicting real-world events, such as changes in a country's gross domestic product (GDP). Quantitative analysis uses statistical techniques to examine and analyze past, current, and anticipated future events. Any subject involving numbers can be quantified; thus there are many fields in which quantitative analysis is used and can be beneficial. Qualitative Analysis - Qualitative analysis is a form of analysis that uses subjective judgment based on information that is difficult to quantify, such as management expertise, industry cycles, strength of research and development, and labor relations. Qualitative analysis contrasts with quantitative analysis and often the two investment techniques are used together to provide multiple perspectives in different investment opportunities. Technical Analysis -Technical Analysis involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific investment securities. The risk of market timing based on technical analysis is that charts will not accurately predict future 9 Form ADV Part 2A  price movements. Current prices of securities often reflect all information known about that security and day-to-day changes in market prices of securities will follow random patterns and, in these cases, may not be predictable with any reliable degree of accuracy. Cyclical Analysis - Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. The lengths of economic cycles are difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Investment Strategies and Implementation Signal Ridge believes that allocating capital across a diverse range of asset classes is critical to a client’s long-term investment success. Asset allocation portfolios are created to align with a client’s specific investment objective and risk tolerance. Each portfolio is constructed using a strategic asset allocation methodology with prevailing long-term trends in mind. Short-term trends and trading strategies may be considered depending on the individual circumstances of each client. Signal Ridge structures portfolios using a proprietary methodology. Signal Ridge believes that clients will benefit from having a portfolio of holdings invested in a variety of assets classes that respond differently to major market drivers, such as economic growth, inflation, interest rates and geopolitical circumstances. To the extent that these asset classes are diversifying to each other the overall portfolio will experience lower volatility than the volatility of those asset classes individually. Signal Ridge does not pursue strategies that are highly speculative in nature. Risk of Loss Investing in securities involves risks, including the loss of capital. Securities will and do fluctuate in value. Clients should understand and be prepared for these fluctuations in value as well as for the potential of loss. Signal Ridge assists clients in determining an appropriate asset allocation strategy based primarily on their risk tolerance and time horizon. Even with these methods in place, there is no guarantee that a client will meet or exceed their investment goals. Signal Ridge will continually review a client's investment goals, financial situation, time horizon, tolerance for risk and other factors at least annually to determine if the current asset allocation is still appropriate for that client. A client’s participation and understanding of the process, including full and accurate disclosure of any and all relevant information, is an essential piece for the client to understand the risks involved. Signal Ridge relies heavily on the information provided by the client in determining the appropriateness of any investment portfolio. Therefore, the responsibility lies with the client to relay accurate and up to date information to Signal Ridge. This information should include any material changes in the client’s financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each client in advance of investing the client’s assets. Examples of Risk Across the Capital Markets The following are some of the basic risks associated with the asset classes mentioned in Item 4 of this ADV Part 2. Each investment has its own specific risks, and those risks will vary by investment. Market Risk - All securities are subject to market, economic, liquidity and other risks. The market price of a security may fluctuate throughout the day and may vary by exchange. The success of a particular 10 Form ADV Part 2A  investment depends upon an accurate assessment of the future path of price movements of individual securities. While performance of individual securities is assessed, individual security performance should also be viewed within the context of the overall portfolio. There can be no assurance that Signal Ridge will be able to predict price movements accurately. Authorized Participant Concentration Risk. Only an Authorized Participant may engage in creation or redemption transactions related to underlying Exchange-Traded Fund and Exchange-Traded Note transactions, and none of those Authorized Participants is obligated to engage in creation and/or redemption transactions. To the extent that Authorized Participants exit the business or are unable to proceed with creation or redemption orders with respect to the Fund and no other Authorized Participant is able to step forward to create or redeem Creation Units, Exchange-Traded Fund and Exchange-Traded Note shares may be more likely to trade at a premium or discount to NAV and possibly face trading halts or delisting. Capital risk — Investment markets are subject to economic, regulatory, market sentiment, and other risks. All investors should consider the risks that may impact on their capital, before investing. The value of your investment may become worth more or less than at the time of the original investment. Commodity risk — Commodities markets can be more volatile than traditional investments such as equity or fixed income securities. Commodities may be affected by changes in overall market movements, interest rate changes, and/or events affecting a specific commodity and/or industry. Counterparty risk — risk that one party to a transaction might default on its contractual obligation. Counterparty risk can increase for those transactions not executed on a regulated exchange. Default risk — is the risk that a company or an individual security will be unable to make the required payments on their debt obligation. Lenders and investors are exposed to default risk in virtually all forms of credit extensions. Company risk — Common stocks of individual companies are subject to many risk factors including, but not limited to, economic conditions, government regulations, market risk, and industry risk. Equity security prices may decline as a result of adverse changes in these and other factors. Some equities are more volatile than others and may present a higher risk of loss. Credit risk — The value of fixed income securities may decline, and/or the issuer or guarantor of that security may fail to pay interest or principal when the payments are due. As a general rule, lower rated securities carry a greater degree of credit risk, and therefore have a greater risk of loss, than higher-rated securities. Currency risk — Investments that are held or exposed to foreign currency, are exposed to fluctuations in a foreign exchange rate or rates in addition to the risks associated with the specific underlying investment. Derivative risk — Derivatives involve various degrees of risk. The value of derivative investments can be affected by market movements, the underlying companies, changes in interest rates, and/or factors affecting the underlying security. Derivatives can also involve liquidity risk and expiration/time risk. Equity market risk — Equity markets are subject to many risk factors, including economic conditions, government regulations, market sentiment, local and international political events, and environmental and technological issues. Exchange-Traded Fund and Exchange -Traded Note risk – Exchange-Traded Funds and Exchange- Traded Notes contain a range of risks. Those risks include, but are not limited to, price fluctuation of the underlying securities, liquidity risk which may cause difficulty transacting in these securities at a 11 Form ADV Part 2A  fair market price, and passive investing risk which limits the ability of the underlying investment manager to deviate market exposures from the underlying index. Exchange-Traded Funds and Exchange-Traded Notes prices will fluctuate throughout the trading day; commissions may be charged when trading Exchange-Traded Funds and Exchange- Traded Notes. Fixed Income risk — risks associated with fixed income securities may include, but are not limited to, economic conditions, government regulations, credit worthiness, and fluctuations in interest rates. The secondary market value of fixed income securities will fluctuate with changes in interest rates, liquidity, and the creditworthiness of the specific issuer. Foreign Market risk — Foreign investments present risks that include changes in currency exchange rates, liquidity, economic, and political uncertainty. These risks may be greater in emerging markets. Interest Rate risk —Changes in interest rates will affect investment values. This volatility will typically be greater for long-term fixed income securities than for short-term fixed income securities. Changes in interest rates may also affect the value of other financial assets. Issuer risk — A security issued by a particular issuer may be impacted by factors that are unique to that issuer and thus may cause that security’s return to differ from that of the market. Liquidity risk — Investments with low liquidity can have significant changes in market value, and there is no guarantee that these securities can be sold at fair market value. Management risk — Investment strategies implemented by a management team of a specific investment fund that doesn’t perform as expected may underperform or suffer significant losses. Management risks may also include personnel turnover of specific individuals hired to manage a fund. Tracking risk — The volatility in the performance of an investment relative to its index/benchmark because of various factors which may include, but are not limited to, active management decisions associated with the underlying investments and fees. Examples of Types of Risk Associated with Signal Ridge’s Commonly Used Investment Vehicles Mutual Funds - Market risk, Management risk, Tracking risk. Mutual Funds are investment vehicles that contain/hold other investments and may be limited by their investment strategies, and a Mutual Fund's price may fluctuate based on underlying market conditions, and the pricing of the underlying securities. Exchange Traded Funds (ETFs) - Market risk, Management risk, Tracking risk. ETF’s are investment vehicles that contain/hold other investments allowing them to be traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of an ETF can be lower from that of the underlying securities, that the ETF may be limited by its investment strategy, and that an ETF's price may fluctuate throughout the day. Exchange Traded Notes (ETNs) - Market risk, Counterparty risk, Tracking risk. ETN’s are investment vehicles that contain/hold other investments allowing them to be traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of an ETN 12 Form ADV Part 2A  can be lower from that of the underlying securities, and that an ETN's price may fluctuate throughout the day. Leveraged Exchange Traded Fund and Exchange Traded Notes Leveraged Exchange traded Funds and Exchange Traded Notes contain all the same risks as Exchange Traded Funds and Exchange Traded Notes with the additional risk of amplified losses. Leveraged securities may incur additional costs and will be more volatile relative to unlevered securities. They may be less liquid and, therefore, more difficult to sell at fair market value. REITs - Issuer risk, Liquidity risk, Management risk. REITs are investment vehicles that contain/hold real estate investments allowing them to be traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a REIT can be lower from that of the underlying real estate, and a REITs price may fluctuate throughout the day. Domestic Equities - Market risk, Company risk, Liquidity risk. Domestic Equities are typically traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a domestic equity may fluctuate throughout the day. Foreign Equities - Currency risk, Foreign Market risk, Company risk. Foreign Equities are typically traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a foreign equity may fluctuate throughout the day and overnight, depending on the exchange in which it is traded. Corporate Bonds - Interest Rate risk, Issuer risk, Liquidity risk. Corporate bonds are not traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a corporate bond may fluctuate by the interest rate environment, and credit rating of the issuer. Commercial Paper - Credit risk, Fixed Income risk, Interest Rate risk. Commercial paper is not traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a Commercial paper may fluctuate by the lending/overnight rate environment, and credit rating of the issuer. Certificates of Deposit - Fixed Income risk, Interest Rate risk, Liquidity risk. Certificates of deposit are not traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a certificate of deposit may fluctuate by the interest rate environment, the issuing bank and liquidity risk if sold on the secondary market. Municipal Bonds - Fixed Income risk, Interest Rate risk, Credit risk. Municipal bonds are not traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a municipal bonds may fluctuate by the interest rate environment, the issuing municipality credit rating and taxing authority. 13 Form ADV Part 2A  U.S. Treasuries - Fixed Income risk, Interest Rate risk, Credit risk. U.S. Treasuries are not traded on an exchange as they are issued by the U.S. Government and may be subject to brokerage trading costs, cost efficiency, the market price of a U.S. Treasuries may fluctuate by the interest rate environment, and U.S. currency strength/weakness. Options - Derivative risk, Issuer risk, Liquidity risk. Options are traded on an exchange. They may be subject to brokerage trading costs with market price of an option being derived from the underlying security’s financial strength, volatility, liquidity and the amount of time remaining to the option’s expiration. Signal Ridge, with a client’s approval and the appropriate options agreement on file, may employ options strategies to hedge or gain additional exposure to a particular asset class or sector. Futures - Derivative risk, Issuer risk, Liquidity risk. Futures are traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of the future is driven by the Black Scholes Model with the biggest pricing factors being the underlying index strength and the expiration date. Commodities - Commodity risk, Interest Rate risk, Liquidity risk. Factors that can influence commodity prices include politics, seasons, weather, technology, and market conditions. Preferred Stocks - Interest Rate risk, Issuer risk, Liquidity risk. Preferred stocks are typically traded on an exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a preferred stock may fluctuate by the interest rate environment, and credit rating of the issuer. Utilization of Margin Margin use may be suitable for those clients that have an immediate need for cash and it is determined that accessing capital via the temporary use of margin is a more advantageous course of action than the typical alternative of selling securities. For example, if a client has a personal payment due, does not have sufficient capital on hand to make that payment nor the ability to wait for security sales to settle and capital to become available, then the use of margin to make that payment and interest charges associated with doing so may be more advantageous than paying fees associated with a late payment. Margin would only be used under exceptional circumstances and would typically not exceed 10% of the total net assets of a client’s account. With the client’s approval Signal Ridge may use margin as a tool in managing the liquidity during the rebalancing of client accounts, if needed. Signal Ridge, with a client’s approval and the appropriate options agreement on file will employ options strategies to hedge or gain additional exposure to a particular asset class or sector. 14 Form ADV Part 2A  Item 9: Disciplinary Information Signal Ridge is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of its adviser business or the integrity of management. Signal Ridge has not been the subject of any disciplinary action(s) and does not have any legal or disciplinary information to disclose. Administrative Proceedings There are no administrative proceedings to report. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations Signal Ridge is required to disclose any relationship or arrangement that is material to its adviser business or to its clients with certain related persons. Financial Industry Activities Signal Ridge is not registered as a broker-dealer, and none of its management persons are registered representatives of a broker-dealer. Neither Signal Ridge nor any of its management persons is registered as (or associated with) a futures commissions merchant, commodity pool operator, or a commodity trading adviser. Affiliations – Other Investment Related Activities John F. Smitka, Jr., Chief Compliance Officer, is an Investment Adviser Representative (IAR) of Penguin Global Wealth Management, LLC. Affiliations – Lawyer Mr. Smitka is an attorney and is actively registered with the Massachusetts Board of Bar Overseers. Affiliations – Other Investment Advisers Signal Ridge has no affiliations with other Investment Advisers and receives no compensation for referrals to other Investment Advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Signal Ridge employees must comply with the Code of Ethics and Statement for Insider Trading (“the Code” or “the Code of Ethics”). The Code describes the Firm’s standard of business conduct, and fiduciary duty to its clients. The Code’s key provisions include: • Statement of General Principles 15 Form ADV Part 2A  • Policy on and reporting of Personal Securities Transactions • A prohibition on Insider Trading • Restrictions on the acceptance of significant gifts • Procedures to detect and deter misconduct and violations • Requirement to maintain confidentiality of client information The Firm’s Chief Compliance Officer reviews all employee trades each quarter. These reviews ensure that personal trading does not affect the markets, and that clients of Signal Ridge receive preferential treatment. Signal Ridge’s employees must acknowledge the terms of the Code of Ethics at least annually. Any individual not in compliance with the Code of Ethics may be subject to sanctions, including termination. Clients and prospective clients can obtain a copy of Signal Ridge’s Code of Ethics by contacting John F. Smitka, Jr. at (617) 607-3222. Participation or Interest in Client Transactions – Personal Securities Transactions The Code of Ethics, described above, is designed to assure that the personal securities transactions, activities and interests of the employees of Signal Ridge will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities, primarily mutual funds, have been designated as exempt transactions, based upon the determination that these would materially not interfere with the best interest of Signal Ridge’s clients. In addition, the Code requires pre-clearance of many transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, which is designed to reasonably prevent conflicts of interest between Signal Ridge and its clients. Participation or Interest in Client Transactions – Financial Interest and Principal/Agency Cross It is Signal Ridge’s policy that the Firm will not initiate any principal or agency cross securities transactions for client accounts. Item 12: Brokerage Practices How Signal Ridge Selects Custodians and Brokers Signal Ridge selects custodians and brokers that will hold your assets and execute transactions on terms that are, overall, attractive when compared with other available providers and their services. We consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (without separate fees for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) 16 Form ADV Part 2A  • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our clients Signal Ridge generally recommends that clients utilize the brokerage and clearing services of Pershing, LLC through Pershing Investment Manager Services (“Pershing”) for investment management accounts. Signal Ridge does not receive fees or commissions from this or any custodian or broker arrangement. Best Execution Signal Ridge has a fiduciary duty to seek best execution of securities transactions for client accounts. “Best execution” means seeking to execute transactions so that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. Achieving best execution involves more than obtaining the lowest possible commission rate, especially since commissions do not apply for our Wrap Program; it includes consideration of the overall quality of execution, such as execution speed, accuracy, and financial stability of the broker-dealer. Pershing has a history of best execution performance that is well documented in various publications and testing results. Although Signal Ridge believes Pershing provides competitive execution and pricing, there is no guarantee that the lowest possible transaction cost will be achieved for every trade. Signal Ridge periodically reviews the execution quality of the custodians and broker-dealers it recommends, considering factors such as trade timing, execution accuracy, pricing, and commission rates.. Your Brokerage and Custody Costs For clients in the Wrap Program, there are no brokerage or custody costs charged to the client. Please see the Wrap Program section below with more information on this program. Order Aggregation It is Signal Ridge’s practice to aggregate transactions across multiple client accounts if and when possible. Research and Other Soft Dollar Benefits Signal Ridge does not receive soft dollar benefits from broker/dealers in connection with client securities transactions. Brokerage for Client Referrals Signal Ridge does not receive client referrals from broker/dealers. 17 Form ADV Part 2A  Signal Ridge Wrap Fee Program In evaluating the Wrap Program, a client should recognize that brokerage commissions for the execution of transactions are not negotiated by Signal Ridge. Instead, under the Wrap Program, client accounts are not charged brokerage commissions for securities transactions. Therefore, the annual investment advisory fee covers both Signal Ridge’s investment advisory services and the custodian and brokerage services of Pershing. Signal Ridge pays the costs of Pershing custodial and brokerage services out of the annual investment fee paid by the client. Client Choice in Custodian and Broker Services Signal Ridge has a custody relationship with Pershing. Clients in the Wrap Program primarily custody assets at Pershing. Other factors besides the Wrap Program factor into the decision about whether to custody assets at Pershing– for instance, whether the client already has other assets at that custodian, personal preference, the client portal & app experience, the service experience, the adviser relationship, investment program selection, and other market and non-market related conditions at the time. Item 13: Review of Accounts For those clients to whom Signal Ridge provides investment management services, Signal Ridge monitors those portfolios as part of an ongoing process while regular account reviews are conducted on at least a quarterly basis. Financial planning and/or consulting service reviews may be conducted on a client-directed basis. These reviews are conducted by one of the Signal Ridge Investment Adviser Representatives. All investment management clients are encouraged to discuss their needs, goals, and objectives with Signal Ridge and to keep Signal Ridge informed of any changes thereto. Signal Ridge contacts ongoing investment management clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Clients are provided with regular summary account statements directly from the broker-dealer or custodian for the client accounts. Those clients to whom Signal Ridge provides investment management services may also receive a report from Signal Ridge that may include such relevant account and/or market-related information such as an inventory of account holdings and account performance. Clients should compare the account statements they receive from their custodian with those they receive from Signal Ridge. Those clients to whom Signal Ridge provides financial planning and/or consulting services will receive reports from Signal Ridge summarizing its analysis and conclusions. Item 14: Client Referrals and Other Compensation Signal Ridge is required to disclose any relationship or arrangement where it receives an economic benefit from a third party (non-client) for providing advisory services. In addition, Signal Ridge is required to disclose any direct or indirect compensation that it provides for client referrals. Signal Ridge does not have any required disclosures for this Item. Item 15: Custody Signal Ridge may only implement its discretionary investment management decisions and/or advisory 18 Form ADV Part 2A  recommendations after the client has opened an account at a qualified custodian which can accommodate Signal Ridge’s trading activity on behalf of its clients. Such qualified custodian may be a broker-dealer, a trust company, or a bank. SEC “Custody” Except in the limited instances described below, the Signal Ridge does not have custody of clients’ assets. In the view of the SEC and many state regulators, investment advisers are deemed to have “custody” of client funds if they have the ability to directly debit advisory fees from client accounts. Because, in the case of discretionary portfolio management accounts, the investment adviser has authorization to directly debit the client’s account(s) for payment of advisory fees the investment adviser is said to exercise limited custody over client assets (pursuant to written authorization in the investment advisory agreement). The investment adviser is responsible for assuring that the account’s independent, qualified custodian will provide account statements directly to clients at least quarterly, and that the client’s statement will clearly label the adviser’s fee. In addition, for each case where the fee is directly debited from the client’s account the investment adviser concurrently sends the custodian an invoice or statement of the amount of the fee to be deducted. In addition, as discussed in Item 13, Signal Ridge also makes available periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the custodians and compare them to those received from Signal Ridge. Signal Ridge may also be deemed to have “custody” of client funds if the client has signed a standing letter of authorization (“SLOA”) authorizing the Firm to make certain transfers of client funds to third parties not affiliated with the Adviser. SLOA arrangements are subject to a number of specific safeguards, including (i) the client provides a signed written instruction to the custodian that includes the third party’s name, and either the address or account number to which the transfer should be directed, (ii) the client’s custodian verifies the instruction and promptly provides a transfer of funds notice to the client, (iii) the client has the ability to terminate or change the instruction, (iv) the investment adviser has no authority or ability to designate or change the identity of the third party or any information about the third party, and (v) the client’s custodian reconfirms the instruction annually. Item 16: Investment Discretion In order to provide discretionary investment management services, Signal Ridge must be provided with a limited power of attorney, which is included in the agreement between Signal Ridge and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). Signal Ridge is considered to exercise investment discretion over a client’s account if it can initiate transactions for the client without first having to seek the client’s consent. Signal Ridge takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; and • When transactions are made. 19 Form ADV Part 2A  If Signal Ridge has not been given discretionary authority, Signal Ridge must receive instructions from the client prior to each trade. Item 17: Voting Client Securities Signal Ridge does not vote proxies on behalf of clients. Clients generally retain the responsibility for receiving and voting proxies for securities maintained in their portfolios; clients receive these proxies directly from either custodians or transfer agents. If requested, Signal Ridge may provide advice to clients regarding proxy votes. If any conflict of interest exists, it will be disclosed to the client. Clients may contact Signal Ridge at (617) 607-3222 for information about proxy voting. Item 18: Financial Information Signal Ridge 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. Signal Ridge is not required to provide a balance sheet. Except in the limited manner described herein, Signal Ridge does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1200 per client more than six months in advance. Item 19: Additional Information Privacy Signal Ridge has a Privacy Policy which is distributed to clients annually. Business Continuity Plan (BCP) Signal Ridge has a written BCP that is available to clients and prospects upon request. A written BCP helps identify procedures relating to an emergency or significant business disruption, including death or incapacitation of the investment adviser or any of its representatives. Such procedures are in place to help Signal Ridge meet its fiduciary obligations to its clients. 20 Form ADV Part 2A