STABLEPOINT PARTNERS, LLC

Stablepoint Partners, LLC Form ADV Part 2A – Disclosure Brochure Effective: September 4, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Stablepoint Partners, LLC (“Stablepoint Partners” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (781) 654-4600. Stablepoint Partners 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 Stablepoint Partners to assist you in determining whether to retain the Advisor. Additional information about Stablepoint Partners 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# 328503. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.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 Stablepoint Partners. The Brochure Supplements are provided separately. Stablepoint Partners 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. Stablepoint Partners 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 March 19th, 2025: • The Advisor has amended Items 4 and 14 regarding to reflect its relationship with StoneCastle for cash management services. • The Advisor has amended Items 5 and 10 regarding Stablepoint Insurance, LLC, an affiliated entity under common control and ownership as the Advisor . 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# 328503. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (781) 654-4600. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.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 ........................................................................................................................................... 6 D. Wrap Fee Programs ........................................................................................................................................................ 6 E. Assets Under Management ............................................................................................................................................. 7 Item 5 – Fees and Compensation ......................................................................................................................... 7 A. Fees for Advisory Services.............................................................................................................................................. 7 B. Fee Billing........................................................................................................................................................................ 8 C. Other Fees and Expenses .............................................................................................................................................. 8 D. Advance Payment of Fees and Termination ................................................................................................................... 8 E. Compensation for Sales of Securities ............................................................................................................................. 9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9 Item 7 – Types of Clients ....................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 9 A. Methods of Analysis ........................................................................................................................................................ 9 B. Risk of Loss ................................................................................................................................................................... 10 Item 9 – Disciplinary Information ........................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12 A. Code of Ethics ............................................................................................................................................................... 12 B. Personal Trading with Material Interest ......................................................................................................................... 12 C. Personal Trading in Same Securities as Clients ........................................................................................................... 12 D. Personal Trading at Same Time as Client .................................................................................................................... 12 Item 12 – Brokerage Practices ............................................................................................................................ 13 A. Recommendation of Custodian[s] ................................................................................................................................. 13 B. Aggregating and Allocating Trades ............................................................................................................................... 14 Item 13 – Review of Accounts ............................................................................................................................. 14 A. Frequency of Reviews ................................................................................................................................................... 14 B. Causes for Reviews ...................................................................................................................................................... 14 C. Review Reports ............................................................................................................................................................. 14 Item 14 – Client Referrals and Other Compensation ........................................................................................ 14 A. Compensation Received by Stablepoint Partners ......................................................................................................... 14 B. Compensation for Client Referrals ................................................................................................................................ 14 Item 15 – Custody ................................................................................................................................................. 16 Item 16 – Investment Discretion ......................................................................................................................... 16 Item 17 – Voting Client Securities ....................................................................................................................... 16 Item 18 – Financial Information ........................................................................................................................... 16 Appendix 1 – Wrap Fee Program Brochure ....................................................................................................... 16 Privacy Policy ....................................................................................................................................................... 25 Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 3  Item 4 – Advisory Services A. Firm Information Stablepoint Partners, LLC (“Stablepoint Partners” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware. Stablepoint Partners was founded in August 2023 and became a registered investment advisor in November 2023. Stablepoint Partners is a wholly owned subsidiary of Stablepoint Holdings LLC. Stablepoint is indirectly owned and operated by Christopher K. Griffith, CFP®, CPWA® (Managing Partner, Co- Founder and Chief Compliance Officer) and Henry J. Wheelwright, CFP® (Managing Partner, Co-Founder). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Stablepoint Partners. For information regarding this Disclosure Brochure, please contact Christopher Griffith at (781) 654-4600. B. Advisory Services Offered Stablepoint Partners offers wealth management services including investment management and financial planning services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, and retirement plans (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. Stablepoint Partners’ 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. Wealth Management Services Stablepoint Partners provides customized wealth management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related planning and advisory services. Stablepoint Partners 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. Stablepoint Partners will then construct an investment portfolio, consisting of exchange-traded funds (“ETFs”) and/or mutual funds to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds, unaffiliated money managers (See “Independent Managers” below), alternative investments, and/or other types of investments, as appropriate, to meet the needs of the Client. 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. Stablepoint Partners’ 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. Stablepoint Partners 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. Stablepoint Partners evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Stablepoint Partners may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Stablepoint Partners 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. Stablepoint Partners 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 4  At no time will Stablepoint Partners 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. Use of Independent Managers - Stablepoint Partners may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize enter into an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). 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 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. Participant Account Management – As part of the Advisor’s Wealth Management Services, the Advisor will use a third-party platform to facilitate the discretionary investment management of held away assets such as defined contribution plan participant accounts. The platform enables the Advisor to gain access to the Client account[s] without having access through the Client’s login credentials. The Client will be provided an electronic link that will allow the connection of Client account[s] to the platform. The Advisor is not affiliated with the platform and does not receive any compensation from the platform. Cash Management- Stablepoint Partners 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. Stablepoint Partners will receive a fee from StoneCastle if Clients participate in this program, based upon the Client’s account balance in the FICA Program. Stablepoint Partners may assist clients in signing up for this program and facilitating the transfer of funds between the client’s like-named accounts. Financial Planning Services Stablepoint Partners will typically provide a variety of financial planning and consulting services to Clients as part of its wealth management services. 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 Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 5  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. Stablepoint Partners 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 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 Stablepoint Partners provides 3(21) 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 • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • • Ongoing Investment Recommendation and Assistance These services are provided by Stablepoint Partners 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 Stablepoint Partners’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Stablepoint Partners to provide wealth management services, each Client is required to enter into a wealth management agreement 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 – Stablepoint Partners, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Stablepoint Partners 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 – Stablepoint Partners will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Stablepoint Partners will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 6  Stablepoint Partners includes, in addition to custodial costs, administrative fees, wire fees, trade away transactions, other fees and expenses (herein “Covered Costs together with its wealth management fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Stablepoint Partners Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of March 6, 2025, Stablepoint Partners manages $797,651,995 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid monthly, in advance, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior month and billed in accordance with the following fee schedule: Assets Under Management ($) First $1,000,000 Next $1,000,000 Next $3,000,000 Next $5,000,000 $10,000,000 and Above Annual Rate (%) 1.50% 1.25% 1.00% 0.75% Negotiable The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed annual rate or a fixed annual fee. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Stablepoint Partners will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. 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 wealth management fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. 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. If the Client is required to authorize and enter into a wealth management agreement with an Independent Manage then the terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.75% and are billed quarterly in advance, pursuant to the terms of the retirement plan advisory agreement. Retirement plan 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 7  B. Fee Billing Wealth Management Services Wealth management 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 month. The amount due is calculated by applying the monthly rate (annual rate divided by the number of days in the year, multiplied by the number of days in the month) to the total assets under management with Stablepoint Partners at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to review 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 Stablepoint Partners to be paid directly from their account[s] held by the Custodian as part of the wealth management 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 Stablepoint Partners’ wealth management 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]. 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. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. Stablepoint Partners includes Covered Costs as part of its overall wealth management fee through the Stablepoint Partners Wrap Fee Program. Securities transaction fees for Client-directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure. In addition, all fees paid to Stablepoint Partners for wealth management 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 Stablepoint Partners, but would not receive the services provided by Stablepoint Partners 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 Stablepoint Partners 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 Wealth Management Services Stablepoint Partners may be compensated for its investment management services in advance of the month in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management 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 wealth management fees from the effective date of termination to the end of the month. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 8  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. Stablepoint Partners will assist the Client with the termination and transition as appropriate. Retirement Plan Advisory Services Stablepoint Partners is compensated for its services at the beginning/end of the quarter before/after advisory services are rendered. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Stablepoint Partners 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. Stablepoint Insurance, LLC Stablepoint Insurance, LLC (“Stablepoint Insurance”) is an affiliated entity under common control and ownership as the Advisor. Certain Advisory Persons are licensed as an independent insurance professional through Stablepoint Insurance. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products offered to Clients of the Advisor. Insurance commissions earned by Advisory Person are separate and in addition to investment advisory fees. This practice presents a conflict of interest as an Advisory Person who is also an insurance agent will have an incentive to recommend insurance products to the Client for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractual or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please also see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management Stablepoint Partners does not charge performance-based fees for its wealth management services. The fees charged by Stablepoint Partners are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Stablepoint Partners 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 Stablepoint Partners offers wealth management services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, and retirement plans. Stablepoint Partners generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Stablepoint Partners primarily employs a fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Stablepoint Partners 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. 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 9  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 Stablepoint Partners will be able to accurately predict such a reoccurrence. As noted above, Stablepoint Partners generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Stablepoint Partners 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, Stablepoint Partners 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. 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. Stablepoint Partners 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. 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: 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 have 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 Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 10  in the day may have a different price than the same ETF purchased or sold a short time later. There is also a risk that Authorized Participants are unable to fulfill their responsibilities. Authorized Participants are one of the major parties involved with ETF creation/redemption mechanism in the markets. The Authorized Participants play a critical role in the liquidity of ETFs and essentially have the exclusive right to change the supply of ETF shares in the market. If the Authorized Participants does not fulfill this expected role, there could be an adverse impact on liquidity and the valuation of an ETF. Bond Risks Bonds 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. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) 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. Digital Assets Risks Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable for Clients with a high risk tolerance. 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 Stablepoint Partners or its management persons. Stablepoint Partners 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# 328503. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 11  Item 10 – Other Financial Industry Activities and Affiliations Stablepoint Insurance, LLC As noted in Item 5, Stablepoint Insurance, LLC (“Stablepoint Insurance”) is an affiliated entity under common control and ownership as the Advisor. Certain Advisory Persons are a licensed insurance professional through Stablepoint Insurance. Implementations of insurance recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset investment advisory fees. This 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 Advisor or Advisory Persons. Use of Independent Managers As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. The Advisor does not receive any compensation nor does this present a material conflict of interest. The Advisor will only earn its wealth management fee as described in Item 5.A. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Stablepoint Partners 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 Stablepoint Partners (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Stablepoint Partners and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Stablepoint Partners’ 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 (781) 654-4600. B. Personal Trading with Material Interest Stablepoint Partners allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Stablepoint Partners 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. Stablepoint Partners does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Stablepoint Partners 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 Stablepoint Partners 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 Stablepoint Partners 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 Stablepoint Partners, or any Supervised Person of Stablepoint Partners, transact in any security to the detriment of any Client. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 12  Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Stablepoint Partners 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 Stablepoint Partners to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, Stablepoint Partners does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Stablepoint Partners does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Stablepoint Partners. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Stablepoint Partners 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. Stablepoint Partners may recommend the Custodian based on criteria such as, but not limited to, the 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. Stablepoint Partners will generally recommend that Clients establish their account[s] at Goldman Sachs Custody Solutions and related divisions and entities of Goldman Sachs & Co., Inc. (collectively “Goldman”) or Charles Schwab & Co Inc. (“Schwab”), each a FINRA-registered broker-dealer and member SIPC. Goldman or Schwab (herein collectively the “Custodians”) will serve as the Client’s “qualified custodian”. Stablepoint Partners maintains an institutional relationship with the Custodians, whereby the Advisor receives economic benefits from the Custodians. Stablepoint Partners has established an institutional relationship with the Custodians to assist the Advisor in managing Client account[s]. Access to the Custodians’ platform is provided at no charge to the Advisor. The Custodians platform includes brokerage, custody, administrative support, record keeping, technology and related services designed to support registered investment advisors like Stablepoint Partners in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. Goldman may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. Goldman enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no- load funds at nominal transaction charges. Goldman’s commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Goldman may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. 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. Stablepoint Partners does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodians. Please see Item 14 below. 2. Brokerage Referrals - Stablepoint Partners 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 Stablepoint Partners 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]). Stablepoint Partners will not be obligated to select Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 13  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. 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. Stablepoint Partners will execute its transactions through the Custodian as authorized by the Client. Stablepoint Partners 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 Stablepoint Advisors and periodically by the CCO. 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 Stablepoint Partners 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 Stablepoint Partners Stablepoint Partners may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Stablepoint Partners may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform - Goldman As noted in item 12, Stablepoint Partners has established an institutional relationship with Goldman to assist the Advisor in managing Client account[s]. As part of the arrangement, Goldman also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Goldman directly from independent research companies. The Advisor may also receive additional services and support from Goldman. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Goldman's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Goldman and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders wealth management services to Clients that maintain assets at Goldman The software and related systems support may benefit Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 14  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. In addition, Goldman has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. Participation in Institutional Advisor Platform - Schwab As noted in Item 12, Stablepoint Partners has also established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Stablepoint Partners. As a registered investment advisor participating on the Schwab Advisor Services platform, Stablepoint Partners 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. 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 support to Stablepoint Partners that may not benefit the Client, including: educational conferences and events, 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. Stablepoint Partners believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Compensation Received from Unaffiliated Third-Parties The Advisor may receive financial support from unaffiliated third parties, including certain Independent Managers used in Client Portfolios. This support is exclusively allocated to cover costs associated with hosting Client events. These third parties may also participate in these events, offering educational seminars and materials tof Clients. Clients should be aware that receiving financial support from these unaffiliated third parties presents a conflict of interest, as it can influence the Advisor's preference for these third parties over similar providers. The Advisor is dedicated to acting as a Fiduciary and will only make recommendations that are in the Client's best interests. Clients are not obligated to use any of these unaffiliated third parties. Cash Management As stated above, Stablepoint Partners 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. Stablepoint Partners will receive a fee from StoneCastle if Clients participate in this program, based upon the Client’s account balance in the FICA Program. Stablepoint Partners is not affiliated with the Cash Management Programs or any of the program’s banks. Stablepoint Partners 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 15  B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Stablepoint Partners 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 Stablepoint Partners 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 Stablepoint Partners 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 Stablepoint Partners to ensure accuracy, as the Custodian does not perform this review. Item 16 – Investment Discretion Stablepoint Partners 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 Stablepoint Partners. 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 a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by Stablepoint Partners will be in accordance with each Client’s investment objectives and goals. Item 17 – Voting Client Securities Stablepoint Partners does not accept proxy-voting responsibility for any Client. 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. Item 18 – Financial Information Neither Stablepoint Partners, nor its management, have any adverse financial situations that would reasonably impair the ability of Stablepoint Partners to meet all obligations to its Clients. Neither Stablepoint Partners, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Stablepoint Partners 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 16  Stablepoint Partners, LLC Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”) Effective: September 4, 2025 This Form ADV2A – Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices for Stablepoint Partners, LLC (“Stablepoint Partners” or the “Advisor”) services when offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the Stablepoint Partners Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the complete Stablepoint Partners Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure or the Stablepoint Partners Disclosure Brochure, please contact the Advisor at (781) 654-4600. Stablepoint Partners is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Wrap Fee Program 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 Wrap Fee Program Brochure provides information about Stablepoint Partners to assist you in determining whether to retain the Advisor. Additional information about Stablepoint Partners and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD# 328503. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 17  Item 2 – Material Changes Form ADV 2A – Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program offered by the Advisor. Material Changes There have been no material changes to this Wrap Fee Program Brochure since the last annual amendment filing on March 19th, 2025. Future Changes From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete Stablepoint Partners Disclosure Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Stablepoint Partners. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 328503. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (781) 654-4600. Item 3 – Table of Contents Item 2 – Material Changes ................................................................................................................................... 17 Item 3 – Table of Contents ................................................................................................................................... 17 Item 4 – Services Fees and Compensation ........................................................................................................ 18 Item 5 – Account Requirements and Types of Clients ..................................................................................... 19 Item 6 – Portfolio Manager Selection and Evaluation ....................................................................................... 19 Item 7 – Client Information Provided to Portfolio Managers ............................................................................ 21 Item 8 – Client Contact with Portfolio Managers ............................................................................................... 21 Item 9 – Additional Information ........................................................................................................................... 21 Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 18  Item 4 – Services Fees and Compensation A. Services Stablepoint Partners, LLC (Stablepoint Partners” or the “Advisor”) provides customized wealth management services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the Stablepoint Partners Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting Stablepoint Partners as your investment advisor. As part of the wealth management fees noted in Item 5 of the Disclosure Brochure, Stablepoint Partners includes securities transaction fees (herein “Covered Costs”) as part of the overall wealth management fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of Covered Costs into a single “bundled” wealth management fee. This Wrap Fee Program Brochure references back to the Stablepoint Partners Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on Stablepoint Partners’ investment philosophy and related services. B. Program Costs Advisory services provided by Stablepoint Partners are offered in a wrap fee structure whereby Covered Costs are included in the overall wealth management fee paid to Stablepoint Partners. As the level of activity in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the Client is not charged more if there is higher trading activity or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to limit the number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction fees. Therefore, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. C. Fees Wealth management fees are paid monthly, in advance, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior month and are billed in accordance with the following fee schedule: Assets Under Management ($) Up to $1,000,000 $1,000,001 to $2,000,000 $2,000,001 to $5,000,000 $5,000,001 to $10,000,000 Over $10,000,000 Annual Rate (%) 1.50% 1.25% 1.00% 0.75% Negotiable The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed annual rate or a fixed annual fee. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Stablepoint Partners will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary investment management services provided by Stablepoint Partners, as part of its overall wealth management fee. In addition, all fees paid to Stablepoint Partners for wealth management services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 19  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. Securities transaction fees for Client- directed trades will be charged back to the Client. In connection with the discretionary investment management services provided by Stablepoint Partners, the Client will incur other costs assessed by the Custodian or other third parties, other than the Covered Costs noted above, such as wire transfer fees, fees for trades executed away from the Custodian and other fees. The Advisor does not control nor share in these fees. the Client should review both the fees charged by the fund[s] and the fees charged by Stablepoint Partners to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure). D. Compensation Stablepoint Partners is the sponsor and portfolio manager of this Wrap Fee Program. Stablepoint Partners receives wealth management fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management of the Client’s account[s]. Item 5 – Account Requirements and Types of Clients Stablepoint Partners offers wealth management services to individuals, high net worth individuals, trusts, estates, charitable organizations, and businesses. Stablepoint Partners generally does not impose a minimum account size for establishing a relationship. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional information. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection Stablepoint Partners serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. Related Persons Stablepoint Partners personnel serve as portfolio managers for this Wrap Fee Program. Stablepoint Partners does not serve as a portfolio manager for any third-party Wrap Fee Programs. Performance-Based Fees Stablepoint Partners does not charge performance-based fees for its wealth management services. The fees charged by Stablepoint Partners are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Stablepoint Partners 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. Supervised Persons Stablepoint Partners Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure. Methods of Analysis Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the research and analysis methods employed by the Advisor. 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. Stablepoint Partners 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. 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 Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 20  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: 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 have 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. There is also a risk that Authorized Participants are unable to fulfill their responsibilities. Authorized Participants are one of the major parties involved with ETF creation/redemption mechanism in the markets. The Authorized Participants play a critical role in the liquidity of ETFs and essentially have the exclusive right to change the supply of ETF shares in the market. If the Authorized Participants does not fulfill this expected role, there could be an adverse impact on liquidity and the valuation of an ETF. Bond Risks Bonds 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 21  Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client’s margin accounts decline in value, the Client could be subject to a “margin call”, pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) 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. Digital Assets Risks Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable for Clients with a high risk tolerance. 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. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks. Proxy Voting Stablepoint Partners does not accept proxy-voting responsibility for any Client. 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. Item 7 – Client Information Provided to Portfolio Managers Stablepoint Partners is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see the Stablepoint Partners Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers Stablepoint Partners is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at Stablepoint Partners. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations There are no legal, regulatory or disciplinary events involving Stablepoint Partners or its management persons. Stablepoint Partners 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# 328503. Please see Item 9 of the Stablepoint Partners Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the background of the Advisor and its Advisory Persons. Other Financial Activities and Affiliations Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure). Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 22  B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Stablepoint Partners has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons subject to Stablepoint Partners’ compliance program (our “Supervised Persons”). Complete details on the Stablepoint Partners Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Investments in Review of Accounts Client accounts are monitored on a regular and continuous basis by Advisory Persons of Stablepoint Partners under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure. Other Compensation Stablepoint Partners will generally recommend that Clients establish their account[s] at Goldman Sachs Custody Solutions and related divisions and entities of Goldman Sachs & Co., Inc. (collectively “Goldman”) or Charles Schwab & Co Inc. (“Schwab”), each a FINRA-registered broker-dealer and member SIPC. Goldman or Schwab (herein collectively the “Custodians”) will serve as the Client’s “qualified custodian”. Stablepoint Partners maintains an institutional relationship with the Custodians, whereby the Advisor receives economic benefits from the Custodians. Participation in Institutional Advisor Platform- Goldman Stablepoint Partners has established an institutional relationship with Goldman to assist the Advisor in managing Client account[s]. As part of the arrangement, Goldman also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Goldman directly from independent research companies. The Advisor may also receive additional services and support from Goldman. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Goldman’s services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Goldman and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders wealth management services to Clients that maintain assets at Goldman 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. In addition, Goldman has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. Participation in Institutional Advisor Platform – Schwab As noted in Item 12, Stablepoint Partners has also established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Stablepoint Partners. As a registered investment advisor participating on the Schwab Advisor Services platform, Stablepoint Partners 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 potential 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. 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 23  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 support to Stablepoint Partners that may not benefit the Client, including: educational conferences and events, 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 potential conflict of interest. Stablepoint Partners believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Compensation Received from Unaffiliated Third-Parties The Advisor may receive financial support from unaffiliated third parties, including certain Independent Managers used in Client Portfolios. This support is exclusively allocated to cover costs associated with hosting Client events. These third parties may also participate in these events, offering educational seminars and materials tof Clients. Clients should be aware that receiving financial support from these unaffiliated third parties presents a conflict of interest, as it can influence the Advisor's preference for these third parties over similar providers. The Advisor is dedicated to acting as a Fiduciary and will only make recommendations that are in the Client's best interests. Clients are not obligated to use any of these unaffiliated third parties. Please see Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on additional compensation that may be received by Stablepoint Partners or its Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on any outside business activities and the associated compensation. Client Referrals from Solicitors The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Financial Information Neither Stablepoint Partners, nor its management, have any adverse financial situations that would reasonably impair the ability of Stablepoint Partners to meet all obligations to its Clients. Neither Stablepoint Partners, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Stablepoint Partners 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 24  Privacy Policy Effective: September 4, 2025 Our Commitment to You Stablepoint Partners, LLC (“Stablepoint Partners” 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. Stablepoint Partners (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. Stablepoint Partners 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 questionnaires and suitability Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment 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. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 25  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 to: processing No Not Shared Yes Yes 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 transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Stablepoint Partners 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 Stablepoint Partners 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]. No Not Shared Information About Former Clients Stablepoint Partners 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 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 us at (781) 654-4600. Stablepoint Partners, LLC 45 Braintree Hill Park, Suite #402, Braintree, MA 02184 Phone: (781) 654-4600 | Website: https://stablepointpartners.com Page 26