SOVEREIGN FINANCIAL GROUP, INC.

Sovereign Financial Group, Inc. dba Massey Financial Services dba Stone Arch Wealth Advisors, LLC dba Chedester Financial dba Venture Stone Wealth Management dba Tailored Wealth Form ADV Part 2A – Disclosure Brochure Effective: October 31, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Sovereign Financial Group, Inc. (“Sovereign” or the “Advisor”). The Advisor conducts business under various practice names (“doing business as” or “dba” names), including Massey Financial Services, Stone Arch Wealth Advisors, LLC, and Chedester Financial. If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (888) 765-8180. Sovereign is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Sovereign to assist you in determining whether to retain the Advisor. Additional information about Sovereign and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 294314. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: (888) 765-8180 * Fax: (888) 765-8195  www.sfgroupinc.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Sovereign. Sovereign believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Sovereign encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on 3/18/2025: • Christopher Mortara has been appointed as the Chief Compliance Officer of the Advisor, effective June 2025. • The Advisor has amended Item 5 to update fees it collects. Please see this item for additional information. • The Advisor has amended Item 5 to update the calculation methodology for advisory fees. Please see Item 5 for more details. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 294314. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (888) 765-8180. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................. 1 Item 2 – Material Changes....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 3 Item 4 – Advisory Services ..................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 7 D. Wrap Fee Programs ........................................................................................................................................................ 7 E. Assets Under Management ............................................................................................................................................. 7 Item 5 – Fees and Compensation ........................................................................................................................... 7 A. Fees for Advisory Services.............................................................................................................................................. 7 B. Fee Billing........................................................................................................................................................................ 9 C. Other Fees and Expenses ............................................................................................................................................ 10 D. Advance Payment of Fees and Termination ................................................................................................................. 10 E. Compensation for Sales of Securities ........................................................................................................................... 11 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................. 11 Item 7 – Types of Clients....................................................................................................................................... 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 11 A. Methods of Analysis ...................................................................................................................................................... 11 B. Risk of Loss ................................................................................................................................................................... 13 Item 9 – Disciplinary Information ......................................................................................................................... 14 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 15 A. Code of Ethics ............................................................................................................................................................... 15 B. Personal Trading with Material Interest ......................................................................................................................... 15 C. Personal Trading in Same Securities as Clients ........................................................................................................... 15 D. Personal Trading at Same Time as Client .................................................................................................................... 15 Item 12 – Brokerage Practices ............................................................................................................................. 16 A. Recommendation of Custodian[s] ................................................................................................................................. 16 B. Aggregating and Allocating Trades ............................................................................................................................... 17 Item 13 – Review of Accounts .............................................................................................................................. 17 A. Frequency of Reviews ................................................................................................................................................... 17 B. Causes for Reviews ...................................................................................................................................................... 17 C. Review Reports ............................................................................................................................................................. 17 Item 14 – Client Referrals and Other Compensation ......................................................................................... 17 A. Compensation Received by Sovereign ......................................................................................................................... 17 B. Compensation for Client Referrals ................................................................................................................................ 18 Item 15 – Custody .................................................................................................................................................. 18 Item 16 – Investment Discretion ........................................................................................................................... 18 Item 17 – Voting Client Securities ........................................................................................................................ 18 Item 18 – Financial Information ............................................................................................................................ 19 Privacy Policy......................................................................................................................................................... 20 Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 3  Item 4 – Advisory Services A. Firm Information Sovereign Financial Group, Inc. (“Sovereign” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Corporation under the laws of the State of Connecticut. Sovereign was founded in July 2003 and is owned and operated by Charles Failla, Managing Member. The Advisor conducts business under (“doing business as” or “dba” names) of Massey Financial Services, Chedester Financial, Stone Arch Wealth Advisors, LLC, and Venture Stone Wealth Management. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Sovereign. B. Advisory Services Offered Sovereign offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, retirement plans, and a registered investment company (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Sovereign's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Sovereign provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. Sovereign works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Sovereign will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Sovereign’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Sovereign will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Sovereign evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Sovereign may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Sovereign may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Sovereign may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Sovereign accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 4  provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Cash Management Sovereign makes available to clients the FICA For Advisors cash management program with the brand name KEEP (“FICA Program”) offered by StoneCastle Network, LLC (“StoneCastle”), an affiliate of StoneCastle Cash Management, LLC. The FICA Program allows customers the ability to protect their money by placing it in deposit accounts at banks, savings institutions and credit unions (collectively, “Insured Depositories”) in a manner that maintains full insurance of the funds by the Federal Deposit Insurance Corporation (“FDIC”) or National Credit Union Administration (“NCUA”), whichever is applicable. Funds will be deposited within StoneCastle’s network of Insured Depositories (“Deposit Network”). StoneCastle requires no minimum deposit to open a FICA Program account. Sovereign may earn a fee from StoneCastle if clients participate in this program. Sovereign will assist clients in signing up for this program and facilitating the transfer of funds between the client’s like-named accounts. Sovereign also makes available to clients the Flourish Cash program. Flourish Cash is an online cash management solution that seeks to provide Clients with competitive APY and elevated FDIC coverage for their deposits placed at program banks. Flourish Cash is offered by Flourish Financial LLC, a registered broker-dealer and FINRA member. Sovereign is not affiliated with Flourish or any of the program’s banks. Sovereign is not acting as an investment advisor representative or in a discretionary manner when inviting Clients to use Flourish and only does so with Client consent. Use of Independent Managers Sovereign will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Client’s investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Financial Planning Services Sovereign will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Sovereign may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 5  not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Sovereign provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Oversight Services (ERISA 3(21)) Investment Management Services (ERISA 3(38)) Investment Selection and Analysis ● ● ● ● ● Benchmarking Services These services are provided by Sovereign serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Sovereign’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Registered Fund Advisory Services Sovereign acts as investment manger to the Align Alternative Access Fund (the “Fund”), a Delware business trust, registered under the Investment Company Act of 1940 as a continuously offered, non-diversified, closed-end management investment company. Conflicts of interest The Advisor (and its affiliates) and the Portfolio Manager (and the portfolio managers for other clients managed by the Advisor or its affiliates) manage the assets of and/or provide advice to individual accounts, as well as to the Fund. The Fund has no interest in the activities of the Adviser's other clients. In addition, the Advisor and its affiliates, and any of their respective officers, directors, partners, members or employees, may invest for their own accounts in various investment opportunities, including in investment funds, private investment companies or other investment vehicles in which the Fund will have no interest. However, there are no affiliations or arrangements between the Advisor's or its affiliates' clients, the pooled investment vehicles in which the Fund invests and the asset managers of such pooled investment vehicles. The Advisor will invest assets of individual client accounts in the Fund to meet the investment objectives of an individual client’s account as determined by the Adviser. When the Adviser allocates assets of an individual account managed by the Adviser to the Fund, the Adviser earns an investment management fee from the Fund which creates a conflict of interest for the Adviser. In order to eliminate the possibility that the Adviser earns an investment management fee on both the assets held in the individual client account as well as those same assets invested in the Fund, the Advisor will waive the investment management fee it would otherwise be entitled to on the individual client account in the amount invested by the Advisor in the Fund. The individual client account assets allocated by the Adviser to Fund may incur an investment management fee that is higher/or lower than the Advisor might be able to obtain in the market for a similar asset. However, the Adviser believes that the waiver of the Adviser’s investment management fee on the Individual client account assets invested in the Fund will improve the cost effectiveness of the Fund investment. However, there is no guarantee that there is a more cost effective available in the marketplace. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 6  C. Client Account Management Prior to engaging Sovereign to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Sovereign, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Sovereign will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Sovereign will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Sovereign will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Sovereign does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Sovereign. E. Assets Under Management As of December 31, 2024, Sovereign manages $882,702,145 in Client assets, $850,159,821 of which are managed on a discretionary basis and $32,542,324 on a non-discretionary basis. Sovereign also has Assets Under Advisement of $7,757,311. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one more written agreement with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, in advance or in arrears of each calendar billing period pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range up to 3.00% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first billing period. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Sovereign will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Align Alternative Access Fund (the “Fund”) Pursuant to the Advisory Agreement, and in consideration of the advisory services provided by the Advisor to the Fund, the Advisor is entitled to a Management Fee calculated at an annual rate of 0.50% of the Fund's average daily net assets. The Management Fee will be payable monthly in arrears. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 7  The Advisor and the Fund have entered into an Expense Limitation Agreement under which the Advisor has agreed, until at least January 1, 2027, to waive its management fees and to pay or absorb the ordinary operating expenses of the Fund (excluding borrowing costs, dividends and interest on securities sold short, brokerage commissions, acquired fund fees and expenses and extraordinary expenses, including litigation costs), to the extent that its management fees plus the Fund's ordinary annual operating expenses exceed 0.95% per annum of the Fund's average daily net assets attributable to shares. Such Expense Limitation Agreement may not be terminated by the Advisor, but it may be terminated by the Board, upon written notice to the Advisor. Cash Management As disclosed above, Sovereign may be compensated for offering the StoneCastle cash management solution. Clients that have 1 million or more in assets under management with Sovereign will not be charged a fee for this service. For clients with less than 1 million in assets under management the fee for this service is 0.20% and is billed as of the last day of the quarter or on the average daily balance of assets as of end of day in client account(s) invested in the StoneCastle account. Sovereign receives an admin/service annual fee of 0.20% of the value of the Client’s Flourish Cash account if a Client participates in the cash management program from Flourish. This fee is deducted from the Client’s overall APY. This fee may be negotiable or waived at the sole discretion of the Advisor, and is separate from Sovereign’s investment advisory fee disclosed above. Investment Advisor Representatives of Sovereign may also provide cash management services to Clients at the Clients directed custodian. The fee for cash management services is an annual fee of 0.20%. Fees are based on the market value of assets under management at the end of the prior calendar quarter. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. The Advisor will allocate a portion of the advisory fee collected to the Independent Manager pursuant to the terms of the executed agreement between the Advisor and the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 3.00% annually. For clients whom their IAR invests a portion or all their assets in the Sovereign Align Program, the Advisor will administer the Program and perform all trading activities as well as the reinvestment of any dividends or capital gains. For Clients who have elected to have Discretionary accounts, the IAR assigned to the Client will have the ability to utilize the Align program at his/her discretion. Whenever Align is engaged, Client will receive an updated Client Assets and Advisor Services Register. Accounts under the Sovereign Align Program will incur the following fees which are in addition to the advisory fees detailed above. The following fees are the standard Align rates and may be discounted at the discretion of the Advisor: Base Align Fees: These allow for unlimited accounts and AUM to be grouped together to optimize trading efficiencies and, if elected, tax efficiencies. .000125 bps of AUM paid quarterly for non-tax sensitive trading. .000250 bps of AUM quarterly for tax sensitive trading. • Flat $45 / Month for unlimited accounts and AUM • • • These fees are assessed at the Portfolio Group level. Advanced Trading Fees: These fees are for more complex trading strategies including, but not limited to: option overlay strategies, short selling strategies, laddered bonds, alternative / non-publicly traded investments, etc. .000250bps of AUM quarterly. • • These fees are assessed at the account level and are in addition to the base fees detailed above. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 8  Financial Planning Services Financial planning services may be included with investment management services. Sovereign offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly fees range from $200 to $450 per hour. Fixed fees range from $1,500 to $10,000. Fees for ongoing financial planning engagements range from $500 to $2,500 and are billed quarterly. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00%, and are billed in advance or arrears on a quarterly basis, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by the number of days in the year, then multiplied by the number of days in the quarter) to the total assets under management with Sovereign at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Sovereign to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees may include Sovereign’s investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Align Program When engaging with the Align Program, certain strategies where Client funds are invested, client may be assessed fees by portfolio managers / strategists and/or trading platform providers. In those cases, those fees will be collected by the Advisor and paid to the provider(s) directly. Those fees will be reported to Client on a timely basis. Cash Management Fees for StoneCastle engagements are billed as of the last day of the quarter or on the average daily balance of assets as of end of day in client account(s) invested in the StoneCastle account. Fees for Flourish engagements are deducted from the Client’s overall APY. This fee may be negotiable or waived at the sole discretion of the Advisor, and is separate from Sovereign’s investment advisory fee disclosed above. Fees for Investment Advisor Representatives of Sovereign cash management are based on the market value of assets under management at the end of the prior calendar quarter. Financial Planning Services Financial planning fees are invoiced by the Advisor and are due upon execution of the financial planning agreement. At the discretion of the Advisor fees may be due upon the completion of the agreed upon deliverable[s]. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 9  C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Sovereign, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Sovereign are separate and distinct from these custody and execution fees. The Client is also responsible for any fees associated with third-party data aggregation tools, pursuant to the terms of the investment advisory agreement. In addition, all fees paid to Sovereign for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Sovereign, but would not receive the services provided by Sovereign which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Sovereign to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services and Cash Management Services Sovereign may be compensated for its investment management and cash management services in advance of the quarter, in which services are rendered or at the end of the quarter after services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Client’s engaged with Align that have their fees collect in advance, upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the billing period. Use of Independent Managers In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager. Sovereign will assist the Client with the termination and transition as appropriate. Financial Planning Services Sovereign is compensated for its financial planning services upon completion of the engagement deliverable[s]. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Sovereign is compensated for its services at the beginning or end of the billing period, before or after advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for retirement plan advisory fees up to and Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 10  including the effective date of termination. The Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Sovereign does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the wealth management fees noted above. Certain Advisory Persons are also Registered Representatives of Purshe Kaplan Sterling Investments (CRD#: 35747) (“PKS”). PKS is a registered broker-dealer and member FINRA, SIPC. In an one’s separate capacity as a Registered Representative, an Advisory Person may implement securities transactions under PKS as a transaction account and not through Sovereign in an advisory account. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in one’s capacity as a Registered Representative is separate and in addition to the Advisor’s fees. This practice presents a conflict of interest as the Advisory Person may have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are not obligated to implement any recommendation provided by the Advisor nor its Advisory Persons. Neither the Advisor nor its Advisory Persons will earn ongoing investment advisory fees in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item 10 below. Certain Advisory Persons are also licensed as independent insurance professionals. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by these persons are separate and in addition to advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of the Advisor who are insurance agents have an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations. Item 6 – Performance-Based Fees and Side-By-Side Management Sovereign does not charge performance-based fees for its investment advisory services. The fees charged by Sovereign are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Sovereign does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Sovereign offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, retirement plans, and registered investment fund. The amount of each type of Client is available on Sovereign’s Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Sovereign generally does not impose a minimum relationship size. However, the Advisor imposes a minimum fee for services of $1,125 per quarter. This minimum fee can be waived at the sole discretion of the Advisor. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Sovereign primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Sovereign are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 11  Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Sovereign will be able to accurately predict such a reoccurrence. As noted above, Sovereign generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Sovereign will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Sovereign may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Align Alternative Access Fund (the “Fund”) The Fund is a registered investment company under the Investment Company Act of 1940. As such, the Fund is required to file a registration statement, including a prospectus, and other disclosure documents with SEC. Investors in the fund and potential Fund investors should obtain information regarding the Fund from those documents. SEC requires that sales of shares of the fund must be preceded by a prospectus. The investment objective of the Fund is to provide investors access to tactical exposure to diversified alternative strategies, including but not limited to, private credit, private real estate, private equity, and options strategies. The Fund seeks to achieve its investment objective by investing strategically through direct and indirect investment of its assets in the securities of domestic issuers pursuing alternative strategies (such securities, “Alternatives”). Such Alternatives provide exposure to private credit, private real estate, or private equity strategies. The Fund may also deploy option strategies including, but not limited to, covered calls, short puts, cash-secured puts, and iron- condors. The Fund may also hold its assets in income-oriented securities including, but not limited to, corporate bonds, treasuries, and money market instruments prior to investing such assets in Alternatives. While the Fund typically expects to invest primarily in Alternatives, for tactical reasons the Fund may, at the Advisor’s discretion, invest all of its assets in income-oriented securities. The Advisor seeks to achieve the Fund's investment objective by tactically investing and divesting among the Alternatives categories referenced above. The Advisor anticipates implementing such investment and divestment via dollar-cost averaging but reserves the right to select alternative methods to invest the Fund’s assets. The portion of the Fund’s assets which have not been allocated to Alternatives (or before such portion has been deployed in an Alternatives category) will be invested in income-oriented securities such as corporate bonds, treasuries, and money market instruments. The Advisor believes the Alternatives categories selected for investment will each offer a different mix of liquidity, yield, capital growth, credit risk, and correlation to the broader debt and equity markets. Within each Alternatives category, the Advisor assesses potential yield, capital growth, default risk and expected volatility to construct a portfolio it believes will most effectively support the Fund's investment objective. The Advisor also considers expected correlation of asset class returns when constructing the Fund's portfolio. In addition to considering the expected performance of an asset class held by a public fund or private fund, the Advisor evaluates management Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 12  experience, historical performance and operational expenses. The Advisor will sell a holding for reasons including, but not limited to, to adjust average portfolio maturity, when default risk increases, when yield or capital growth performance is weaker than expected, or when a more attractive replacement is identified. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Sovereign will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in 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 Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Align Alternative Access Fund (the “Fund”) An investment in the Fund involves a considerable amount of risk. Before making an investment decision, a prospective investor should (i) consider the suitability of this investment with respect to his, her or its investment objectives and personal situation and (ii) consider factors such as his, her or its personal net worth, income, age, risk tolerance and liquidity needs. An investment in the Fund's shares represents an indirect investment in the portfolio of private funds, public funds, and fixed-income instruments, short positions and other securities owned by the Fund, and the value of these securities and other instruments may fluctuate, sometimes rapidly and unpredictably, and such investment is subject to investment risk, including the possible loss of the entire principal amount invested. At any point in time, an investment in the Fund's shares may be worth less than the original amount invested, even after taking into account distributions paid by the Fund and the ability of shareholders to reinvest dividends. The Fund may also use leverage, which would magnify the Fund’s investment, market and certain other risks. Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 13  Bond ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Alternative Investments The performance of alternative investments can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For Example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self- liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Sovereign or its owner [OR] management person[s]. Sovereign values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 294314. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons are also Registered Representatives of PKS. In one’s separate capacity as a Registered Representative, an Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by the Advisory Person. Neither the Advisor nor its Advisory Persons will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a Registered Representative. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Sovereign. As an insurance professional, Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 14  the Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. The Advisory Person is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by the Advisory Persons or the Advisor. Cash Management As stated above, Sovereign has made available to clients the StoneCastle FICA Program and Flourish Cash (“Cash Management Programs”), online cash management solutions that seeks to provide Clients with competitive APY and elevated FDIC coverage for their deposits placed at program banks. Sovereign is not affiliated with the Cash Management Programs or any of the program’s banks. Sovereign is not acting as an investment advisor representative or in a discretionary manner when inviting Clients to use the Cash Management Programs, and only does so with Client consent. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Sovereign has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Sovereign (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Sovereign and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Sovereign’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (888) 765-8180. B. Personal Trading with Material Interest Sovereign allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Sovereign does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Sovereign does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Sovereign allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Sovereign requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Sovereign allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Sovereign, or any Supervised Person of Sovereign, transact in any security to the detriment of any Client. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 15  Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Sovereign does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Sovereign to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Sovereign does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Under certain instances, the Client may grant the Advisor limited authority to place trades away from the Custodian. Please see Prime Brokerage Authorization below. Where Sovereign does not exercise discretion over the selection of the Custodian, it may recommend Custodian’s to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Sovereign. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Sovereign may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. As certain Advisory Persons of Sovereign are also Registered Representatives of PKS, the Advisor may be limited in using other broker-dealers/custodians as PKS must approve the use of any outside broker-dealer/custodian. Sovereign will generally recommend that Clients, other than registered fund clients, establish their account[s] at Raymond James & Associates, Inc. (“Raymond James”), member New York Stock Exchange/SIPC, a FINRA- registered broker-dealer, or Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Raymond James or Schwab will serve as the Client’s “qualified custodian”. Sovereign maintains an institutional relationship with Raymond James and Schwab, whereby the Advisor receives economic benefits from Raymond James and Schwab. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Sovereign does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Sovereign does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Sovereign will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Sovereign will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. 4. Directed Brokerage - The Advisor may execute securities transactions either through the Custodian or through another unaffiliated broker-dealer in connection with a prime brokerage relationship established with the Custodian. Should a Client’s account[s] make use of prime brokerage, the Client is required to execute additional agreement[s] with the Custodian authorizing the Advisor to trade-away from and settle to the Client’s established account[s] at the Custodian. The Custodian may charge an additional trade-away fee for these transactions in addition to the normal securities transaction costs. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 16  B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Sovereign will execute its transactions through the Custodian as authorized by the Client. Sovereign may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by advisory persons of Sovereign. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Sovereign if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Sovereign Participation in Institutional Advisor Platform Sovereign has established an institutional relationship with Raymond James (“Custodian”) to assist the Advisor in managing Client account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Raymond James. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Sovereign has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Sovereign. As a registered investment advisor participating on the Schwab Advisor Services platform, Sovereign receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 17  Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Sovereign that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Sovereign believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Sovereign Align Program For accounts where Client assets are invested in the Sovereign Align Program, Sovereign will receive in certain situations additional compensation for trading accounts in the program. This compensation presents a conflict of interest as the Advisor receives more compensation in the Align program than in accounts where an advisor trades in Client accounts. The Advisor mitigates this conflict by ensuring the appropriateness of Clients invested through the Align program. B. Compensation for Client Referrals Sovereign does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Sovereign does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Sovereign exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Sovereign to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Sovereign to ensure accuracy, as the Custodian does not perform this review. Item 16 – Investment Discretion Sovereign generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Sovereign. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Sovereign will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 18  Sovereign does not accept proxy-voting responsibility for any Client, other than the registered fund. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Align Alternative Access Fund (the “Fund”) While it is unlikely that the Fund will receive notices or proxies from Investment Funds (or in connection with any other portfolio securities), to the extent that the Fund does receive such notices or proxies and the Fund has voting interests in such securities, the responsibility for decisions regarding proxy voting for securities held by the Fund lies with the Advisor. The Advisor will vote such proxies in accordance with the Advisor’s proxy policies and procedures Rule 206(4)-6 under the Advisers Act requires a registered investment adviser with voting authority over client proxies to adopt proxy voting policies and procedures, including procedures to address material conflicts of interest, and to disclose such procedures and its specific voting history to clients. Accordingly, the Fund incorporates herein and makes a part hereof the Adviser’s proxy voting policies and procedures. These Policies are to be implemented by the Advisor for the Fund. To the extent that these Policies do not cover potential voting issues with respect to proxies received by the Fund, the Advisor shall act on behalf of the Fund to promote the Fund’s investment objectives, subject to the provisions of these Policies. Item 18 – Financial Information Neither Sovereign, nor its management, have any adverse financial situations that would reasonably impair the ability of Sovereign to meet all obligations to its Clients. Neither Sovereign, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Sovereign is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 19  Privacy Policy Effective: October 31, 2025 Our Commitment to You Sovereign Financial Group, Inc. (“Sovereign” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Sovereign (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Sovereign does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 20  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Sovereign shares Client information with Purshe Kaplan Sterling Investments (“PKS”) due to the oversight PKS has over Supervised Persons of the Advisor. You may also contact us at any time for a copy of the PKS Privacy Policy. Marketing Purposes Sovereign does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Sovereign or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Sovereign does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Massachusetts In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting the Advisor at (888) 765-8180. Sovereign Financial Group, Inc. 35 West Broad Street, Suite 100, Stamford, CT 06902 Phone: 888.765.8180 * Fax: 888.765.8195 www.sfgroupinc.com Page 21