STEINBERGANNA WEALTH MANAGEMENT LLC

ITEM 1: COVER SHEET FORM ADV PART 2A INFORMATIONAL BROCHURE 76 New York Avenue Suite 2 Huntington, NY 11743 (631) 271-6160 February 6, 2026 STEINBERGANNA Wealth Management is the marketing name for SA Wealth Management LLC. This brochure provides information about the qualifications and business practices of STEINBERGANNA Wealth Management. If you have any questions about the contents of this brochure, please contact us at (631) 271-6160. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Our registration does not imply a certain level of skill or training. Additional information about STEINBERGANNA Wealth Management. (CRD# 335680) is also available on the SEC’s website at www.adviserinfo.sec.gov. 1  ITEM 2: STATEMENT OF MATERIAL CHANGES STEINBERGANNA Wealth Management is required to disclose any material changes to this ADV Part 2A here in Item 2. As of the date of this brochure there are no material changes to disclose. ITEM 3: TABLE OF CONTENTS TABLE OF CONTENTS Item 1: Cover Sheet.................................................................................................................... 1 Item 2: Statement of Material Changes ....................................................................................... 2 Item 3: Table of Contents ........................................................................................................... 2 Item 4: Advisory Business........................................................................................................... 3 Item 5: Fees and Compensation ................................................................................................. 4 Item 6: Performance-Based Fees................................................................................................ 6 Item 7: Types of Clients .............................................................................................................. 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss............................................ 7 Item 9: Disciplinary Information ................................................................................................ 11 Item 10: Other Financial Industry Activities and Affiliations ......................................................... 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 12 Item 12: Brokerage Practices ...................................................................................................... 12 Item 13: Review of Accounts ...................................................................................................... 15 Item 14: Client Referrals and Other Compensation ..................................................................... 15 Item 15: Custody ....................................................................................................................... 16 Item 16: Investment Discretion .................................................................................................. 17 Item 17: Voting Client Securities ................................................................................................. 17 Item 18: Financial Information .................................................................................................... 17 2  INFORMATIONAL BROCHURE STEINBERGANNA Wealth Management ITEM 4: ADVISORY BUSINESS SA Wealth Management LLC utilizes the marketing name of STEINBERGANNA Wealth Management (“STEINBERGANNA”, the “Firm”) and is owned by Daniel Steinberg and Kenneth C. Anna that each respectively have over 30 years of experience in the financial services industry. STEINBERGANNA’s mission is to be a trusted resource for clients and believes if you do what’s best for clients it will ultimately be what is best for the Firm. The Firm’s focus is on providing a high level of service to clients and to be the central touch point for clients’ financial decisions. Asset Management When we perform asset management services, we will do so on a discretionary basis. This means that while we continue an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, we will not seek specific approval of changes to client accounts. Because we take discretion when managing accounts, clients engaging us will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an agreement that outlines the responsibilities of both the client and STEINBERGANNA. STEINBERGANNA will gather client investment objectives and financial information through client dialogue and from there tailor an investment portfolio to the specific needs of the client. Clients may place reasonable restrictions on the management of assets, including specific securities or types of securities. However, clients should understand that significant restrictions cannot only decrease the ability of the Firm to meet the client’s goals, but also increase the costs associated with managing the client’s portfolio. In limited circumstances, STEINBERGANNA may provide asset management services on a non- discretionary basis, which means we will manage the clients’ accounts as we do for our discretionary clients, except we will consult with the client prior to implementing any investment recommendation. Clients should be aware that some recommendations may be time-sensitive, in which case recommendations not implemented because we are unable to reach a non- discretionary client may not be made on a timely basis and therefore client’s account may not perform as well as it would have had STEINBERGANNA been able to reach the client for a consultation on the recommendation. Retirement Plans STEINBERGANNA provides educational participant services to retirement plans for business entities. We educate individual participants on how the plan works and can review the investment choices with them. We also work with plan sponsors to assist them in selecting investments to offer in the plan as well as assisting plan sponsors in evaluating providers. Estate and Trust Administrative Assistance 3  STEINBERGANNA assists clients with the administrative tasks associated with establishing estate accounts and trust accounts. STEINBERGANNA does not provide any legal or tax advice and is not involved with the preparation of any legal documents. STEINBERGANNA will coordinate with legal and tax advisors in order to facilitate the establishment of estate and trust accounts. Use of Third-Party Managers STEINBERGANNA may select certain third-party managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages a third-party manager may be set forth in a separate written agreement with the designated third-party manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Third-party managers engaged to manage their assets. STEINBERGANNA evaluates a variety of information about third-party managers, which may include the third-party managers’ public disclosure documents, materials supplied by the third-party managers themselves and other third-party analyses it believes are reputable. To the extent possible, STEINBERGANNA seeks to assess the third-party managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. STEINBERGANNA also takes into consideration each third-party manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. STEINBERGANNA continues to provide services relative to the discretionary selection of the third- party managers. On an ongoing basis, STEINBERGANNA monitors the performance of those accounts being managed by third-party managers. STEINBERGANNA seeks to ensure the third- party managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Fees for the use of third-party managers is separate and in addition to the fee charged by STENBERGANNA. Assets under Management As of December 31, 2025 STEINBERGANNA has $496,364,933 in assets under management across 267 Clients. Of 267 Clients, 656 accounts are managed on a discretionary basis with $469,191,176 in assets under management, and 8 accounts are managed on a non-discretionary basis with $27,173,757 in assets under management. ITEM 5: FEES AND COMPENSATION Fees Charged A. All investment management clients will be required to execute an investment management agreement that will describe the type of management services to be provided and the fees, among other items. Clients are advised that they may pay fees that are higher or lower than fees they may pay another advisor for the same services. Clients are under no obligation at any time to engage or to continue to engage STEINBERGANNA for investment services. If you do not receive a copy of this brochure at least 48 hours prior to the execution of an Agreement, you may terminate the agreement within the first five (5) business days without penalty. Asset Management 4  STEINBERGANNA asset management fees generally range from 0.00% to 1.75% per annum of the net market value of a client’s account managed by STEINBERGANNA billed monthly in advance. Clients may pay a different fee in each account dependent on the assets within that account. Fees are negotiable and may be higher or lower than this range, based on the nature of the account, and the origin of the client. Factors affecting fee percentages include if the account is the size of the account, complexity of asset structures, the non-management services provided to the client, and any other unique factors that may exist. On a limited basis, STEINBERGANNA will charge a fixed fee for asset management services ranging from $500 to $20,000 as determined in the sole discretion of STEINBERGANNA and mutually agreed upon with the client. Retirement Plans STEINBERGANNA retirement plan fees generally range from 0.15% to 1.50% per annum of the total plan assets. Estate and Trust Administrative Assistance STEINBERGANNA will charge a fixed free for assistance with the establishment of estate and trust accounts ranging from $500 to $20,000 as determined in the sole discretion of STEINBERGANNA and mutually agreed upon with the client. Fee Payment B. For clients whose assets are managed by the Firm, asset management fees will be debited directly from each client’s account. The advisory fee is paid monthly, in advance, based on the net market value of a client’s account as of the last day of the previous month’s end. To the extent there is cash in your account, it will be included in the value for the purpose of calculating fees only if the cash is part of an investment strategy. Once the calculation is made, we will instruct your account custodian via written notice to deduct the fee from your account and remit it to STEINBERGANNA. If a third-party manager is used, the fee charged by STEINBERGANNA is in addition to the fee charged by the third-party manager. For clients whose assets are held with outside custodians and where STEINBERGANNA still provides investment advice, the fee is calculated on a quarterly basis, in advance, based on the last quarterly value. Clients can have the fee deducted from the assets held with the custodian for STEINBERGANNA, or by check as mutually agreed upon between the client and STEINBERGANNA. Clients whose fees are directly debited will provide written authorization to debit asset management fees from their accounts held by a qualified custodian chosen by the client. STEINBERGANNA is to invoice the qualified custodian for fees. Each month, the client will receive a statement from their account custodian showing all transactions in their account, including the fee. STEINBERGANNA encourages clients to carefully review the statements and confirmations sent to them by their custodian, and to compare the information on reports prepared by STEINBERGANNA against the information in the statements provided directly from the custodian. Please alert STEINBERGANNA of any discrepancies. Retirement plan fees are calculated by the custodian of the plan and deducted from plan assets. The fees are then paid to STEINBERGANNA from the custodian of the plan. 5  STEINBERGANNA on a limited basis, will charge a fixed fee to a client where the fee is paid annually by the client by check based upon the last annual value. For estate and trust administrative assistance, the Client is issued an invoice for the fixed fee amount agreed upon which can be paid by check or by deduction of the amount from the assets currently under management by STEINBERGANNA. Other Fees C. There are a number of other fees that can be associated with holding and investing in securities. You will be responsible for fees including transaction fees for the purchase or sale of a mutual fund or exchange traded fund, or commissions for the purchase or sale of a stock. Expenses of a fund will not be included in asset management fees, as they are deducted from the value of the shares by the mutual fund manager. For complete discussion of expenses related to each mutual fund, you should read a copy of the prospectus issued by that fund. STEINBERGANNA can provide or direct you to a copy of the prospectus for any fund that we recommend to you. Any fees paid to third-party managers are separate from, and in addition to, fees paid to STEINBERGANNA. Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial issues. Pro-rata Fees D. If you become a client during a billing period, you will pay an asset management fee for the number of days left in that billing period. If you terminate our relationship during a billing period, you will be responsible for the payment of management fees for the portion of the billing period during which you were a client. Once your notice of termination is received, we will assess pro-rated fees for the number of days between the end of the prior billing period and the date of termination to be paid in whatever way you direct (check, wire). STEINBERGANNA will cease to perform services, including processing trades and distributions, upon termination. Assets not transferred from terminated accounts within 30 (thirty) days of termination may be “de-linked”, meaning they will no longer be visible to STEINBERGANNA and will become a retail account with the custodian. Compensation for the Sale of Securities. E. This item is not applicable. ITEM 6: PERFORMANCE-BASED FEES STEINBERGANNA has an agreement with ValueWorks LLC whereby for every year that a client of STEINBERGANNA is invested in ValueWorks Limited Partners, ValueWorks pays STEINBERGANNA 50% of the management fee collected by ValueWorks LLC and an amount equal to 50% of the incentive allocation as described in the offering documents, if ValueWorks LLC takes a performance allocation. STEINBERGANNA will consider the additional fees as part of its diligence and evaluation process in determining whether to recommend that a client invest in ValueWorks Limited Partners. Because STEINBERGANNA will receive compensation because of investments in ValueWorks Limited Partners, STEINBERGANNA has a material conflict of interest when 6  evaluating ValueWorks Limited Partners as a potential investment for a client. We attempt to mitigate this conflict by disclosing it to our clients both in this Form ADV and in a separate written disclosure to all investors that are clients of STEINBERGANNA. Further, all supervised persons of STEINBERGANNA are required to read and follow the firm’s Code of Ethics, which reminds our advisors of their fiduciary duty to place client interests ahead of their own. ITEM 7: TYPES OF CLIENTS include individuals, families, business entities and retirement plans. Clients advised STEINBERGANNA does not have an account minimum. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS It is important for you to know and remember that all investments carry risks. Investing in securities involves risk of loss that clients should be prepared to bear. Each client’s portfolio will be invested according to that client’s investment objectives, which are typically ascertained through discussions with clients regarding investment objectives and documents provided by the client. Once we ascertain your objectives for each account, as well as the portfolio as a whole, we will develop an asset allocation or determine if the use of a third-party manager is appropriate to assist the client in achieving their financial goals. Using fundamental analysis, we base our conclusions on predominantly publicly available research, such as regulatory filings, press releases, competitor analyses, and in some cases research we receive from our custodian or other market analyses. We may periodically recommend changes to the investment strategies and client portfolios to meet the guidelines of the asset allocation for an individual client’s objectives. It is important to remember that because market conditions can vary greatly, your asset allocation may deviate from the guidelines as we believe necessary. There are no limits to the types of securities that may be placed in a strategy, or that STEINBERGANNA may evaluate for a client or for inclusion in a strategy. However, investments most typically include exchange traded funds (ETFs), mutual funds, individual stocks and bonds, and third-party managers. When STEINBERGANNA makes changes to an investment strategy, these changes may not be made simultaneously. Rather, some accounts may be modified before others. This may result in accounts being traded earlier inadvertently having an advantage over accounts traded later or vice versa. Third-Party Managers In some circumstances, STEINBERGANNA can utilize other managers to assist in the management of client assets. These managers are selected by STEINBERGANNA after a process whereby STEINBERGANNA evaluates each manager’s investment performance, operations, and offerings to determine if the manager would be a fit for STEINBERGANNA clients. This process continues on an ongoing basis, throughout the time the client works with the third-party manager. It is important 7  to remember that any fees paid to these managers are separate from, and in addition to, fees paid to STEINBERGANNA. Risk of Loss There are always risks to investing. Clients should be aware that all investments carry various types of risk including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible types of risks. Among the risks are the following: • Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. • General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. • Currency Risk. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio. • Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. • Tax Risks Related to Short Term Trading: Clients should note that STEINBERGANNA may engage in short-term trading transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. STEINBERGANNA endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. • Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk. • Financial Risk. The amount of debt or leverage determines the financial risk of a company. • Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • Margin Risk. “Margin” is a tool used to maximize returns on a given investment by using securities in a client account as collateral for a loan from the custodian to the client. The proceeds of that loan are then used to buy more securities. Margin carries a higher degree of risk than investing without margin. • Risks specific to private placements, sub-advisors and other managers. If we invest some of your assets with another advisor, including a private placement, there are additional risks. These include risks that the other manager is not as qualified as we believe them to be, that the investments they use are not as liquid as we would normally use in your portfolio, or that their risk management guidelines are more liberal than we would normally employ. 8  • Information Risk. All investment professionals rely on research in order to make conclusions about investment options. This research is always a mix of both internal (proprietary) and external (provided by third parties) data and analyses. Even an adviser who says they rely solely on proprietary research must still collect data from third parties. This data, or outside research is chosen for its perceived reliability, but there is no guarantee that the data or research will be completely accurate. Failure in data accuracy or research will translate to a compromised ability by the adviser to reach satisfactory investment conclusions. • Small Companies. Some investment opportunities in the marketplace involve smaller issuers. These companies may be starting up or are historically small. While these companies sometimes have potential for outsized returns, they also have the potential for losses because the reasons the company is small are also risks to the company’s future. For example, a company’s management may lack experience, or the company’s capital for growth may be restricted. These small companies also tend to trade less frequently than larger companies, which can add to the risks associated with their securities because the ability to sell them at an appropriate price may be limited as compared to the markets as a whole. Not only do these companies have investment risk, if a client is invested in such small companies and requests immediate or short-term liquidity, these securities may require a significant discount to value in order to be sold in a shorter time frame. • Concentration Risk. While STEINBERGANNA selects individual securities, including mutual funds, for client portfolios based on an individualized assessment of each security, this evaluation comes without an overlay of general economic or sector specific issue analysis. This means that a client’s equity portfolio may be concentrated in a specific sector, geography, or sub-sector (among other types of potential concentrations), so that if an unexpected event occurs that affects that specific sector or geography, for example, the client’s equity portfolio may be affected negatively, including significant losses. • Transition Risk. As assets are transitioned from a client’s prior advisers to STEINBERGANNA there may be securities and other investments that do not fit within the asset allocation strategy selected for the client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the asset allocation strategy selected by STEINBERGANNA. However, this transition process may take some time to accomplish. Some investments may not be unwound for a lengthy period of time for a variety of reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities or investments that are never able to be sold. The inability to transition a client's holdings into recommendations of STEINBERGANNA may adversely affect the client's account values, as STEINBERGANNA’s recommendations may not be able to be fully implemented. • Restriction Risk. Clients may at all times place reasonable restrictions on the management of their accounts. However, placing these restrictions may make managing the accounts more difficult, thus lowering the potential for returns. • Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had the investment had the opportunity to regain its value. Further, some investments are made with the intention of the investment appreciating over an extended period of time. Liquidating these investments prior to their intended time horizon may result in losses. • REITs: In limited circumstances, STEINBERGANNA may have portions of client portfolios allocated to real estate investment trusts, otherwise known as “REITs”. A REIT is an entity, typically a trust or corporation, that accepts investments from a number of investors, pools the money, and 9  then uses that money to invest in real estate through either actual property purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax benefits, income and the relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also have some increased risks as compared to more traditional investments such as stocks, bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen may have a focus such as commercial real estate or real estate in a given location. Such investment focus can be beneficial if the properties are successful but lose significant principal if the properties are not successful. REITs may also employ significant leverage for the purpose of purchasing more investments with fewer investment dollars, which can enhance returns but also enhances the risk of loss. The success of a REIT is highly dependent upon the manager of the REIT. Clients should ensure they understand the role of the REIT in their portfolio. • International Investing: Investing outside of the United States, especially in emerging markets, can have special or enhanced risks. The most obvious are political risk (changes in local politics can have a vast impact on the markets in that country as well as regulations affecting given issuers) and currency risk (changes in exchange rates between the dollar and the local denominations can materially affect the value of the security even if the underlying fundamentals and market price are stagnant). There are other risks, including enhanced liquidity risk, meaning that while domestic equities and mutual funds are generally easily liquidated (though there may be a risk of loss due to the timing of the sale), equities in other jurisdictions may be subject to the circumstances of lower overall market volume and fewer companies on an emerging exchange. In addition, there may be less information and less transparency in a foreign market or from a foreign company. Foreign markets impose different rules than domestic markets, which may not be to an investor's advantage. Also, companies in foreign jurisdictions are generally able to avail themselves of local laws and venues, meaning that legal remedies for U.S. investors may not be as easily obtained as in the U.S. • Excess Cash Balance Risk: Client accounts may have cash balances in excess of $250,000, which is the insurance limit of the Federal Deposit Insurance Corporation. For cash balances in excess of that amount, there is an enhanced risk that operation related counterparty risk related to the account custodian could cause losses in the account. We mitigate this risk by carrying cash balances in amounts either subject to protection or as limited as you, the client, directs. You may elect to participate in a “cash sweep” program through your account custodian which automatically moves excess cash from your investment account into a cash account and then invests that cash into cash-based investments, such as money market funds. We do not receive compensation of any kind for facilitating your participation in such cash sweep accounts. • Collateralized Mortgage Obligations (“CMOs”) Risks: CMOs are mortgage backed securities (“MBS”) that are collateralized by mortgage loans or mortgage pass-through securities. CMOs are issued in multiple classes, often referred to as “tranches,” with each tranche having specific risk characteristics, payment structures and maturity dates. This creates different prepayment and market risks for each CMO class. The primary risk of CMOs is the uncertainty of the timing of cash flows that results from the rate of prepayments on the underlying mortgages and from the structure of the particular CMO transaction (that is, the priority of the individual tranches). The principal and interest payments on the underlying mortgages may be allocated among the several tranches of a CMO in varying ways including “principal only,” “interest only” and “inverse interest only” tranches. These tranche structures affect the amount and timing of principal and interest received by each tranche from the underlying collateral. For example, an inverse interest-only class CMO entitles holders to receive no payments of principal and to receive interest at a rate that will vary inversely with a specified index or a multiple thereof. Under certain structures, particular classes of CMOs have priority over others with respect to the receipt of prepayments on the mortgages. Therefore, depending on the type of CMOs in which a portfolio invests, the investment may be subject to a greater or lesser risk of prepayment than other types of MBS. 10  ITEM 9: DISCIPLINARY INFORMATION There are no disciplinary items to report. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. Broker-dealer None of the principals of STEINBERGANNA, nor any related persons are registered, or have an application pending to register, as a broker dealer or as an associated person of the foregoing entities. B. Futures Commission Merchant/Commodity Trading Advisor Neither the principals of STEINBERGANNA, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Relationship with Related Persons Certain professionals of STEINBERGANNA are separately licensed as independent insurance agents. As such, these professionals may conduct insurance product transactions for STEINBERGANNA clients, in their capacity as licensed insurance agents, and will receive customary commissions for these transactions in addition to any compensation received in his capacity as employees of STEINBERGANNA. Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees. These professionals therefore have incentive to recommend insurance products based on the compensation to be received, rather than on a client’s needs. The receipt of additional fees for insurance commissions is therefore a conflict of interest, and clients should be aware of this conflict when considering whether to engage STEINBERGANNA or utilize these professionals to implement any insurance recommendations. STEINBERGANNA attempts to mitigate this conflict of interest by disclosing the conflict to clients and informing the clients that they are always free to purchase insurance products through other agents that are not affiliated with STEINBERGANNA, or to determine not to purchase the insurance product at all. STEINBERGANNA also attempts to mitigate the conflict of interest by requiring employees to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty to the clients of STEINBERGANNA, which requires that employees put the interests of clients ahead of their own. STEINBERGANNA also assists business owners from time to time in implementing benefits that help them attract and retain employees. Examples of these benefits (but not limited to) are group sponsored health insurance, dental insurance, life insurance, long and/or short-term disability income insurance, and vision insurance. STEINBERGANNA would then be compensated directly in the form a service fee/commission from the insurance carrier issuing the product. 11  D. Recommendations of other Advisers STEINBERGANNA occasionally recommends other advisers. For more information regarding STEINBERGANNA use of third-party managers, please see response to Item 8 for a full discussion. Shared Space STEINBERGANNA is affiliated with STEINBERGANNA Holdings, LLC which owns the building where STEINBERGANNA conducts business. There are other tenants in the building conducting business but are not affiliated with STEINBERGANNA. STEINBERGANNA Holdings, LLC collects rent from the other tenants in the building. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. Not applicable. STEINBERGANNA does not recommend to clients that they invest in any B. security in which STEINBERGANNA, or any principal thereof has any financial interest. C. On occasion, an employee of STEINBERGANNA may purchase for his or her own account securities which are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. D. On occasion, an employee of STEINBERGANNA may purchase for his or her own account securities which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. ITEM 12: BROKERAGE PRACTICES Recommendation of Broker-Dealer A. 12  STEINBERGANNA does not maintain custody of client assets, though STEINBERGANNA may be deemed to have custody if a client grants STEINBERGANNA authority to debit fees directly from their account (see Item 15 below). Assets will be held with a qualified custodian, which is typically a bank or broker-dealer. STEINBERGANNA primarily recommends that investment accounts be held in custody by Schwab Advisor Services (“Schwab”), which is a qualified custodian. STEINBERGANNA is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when STEINBERGANNA instructs them to, which STEINBERGANNA does in accordance with its agreement with you. While STEINBERGANNA recommends that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. STEINBERGANNA does not open the account for you, although STEINBERGANNA may assist you in doing so. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). How we select brokers/custodians We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including both quantitative (ex: costs) and qualitative (execution, reputation, service) factors. We do not consider whether Schwab or any other broker-dealer-custodian, refers clients to STEINBERGANNA as part of our evaluation of these broker-dealers. Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. In addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). Products and services available to us from Schwab Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like STEINBERGANNA. They provide STEINBERGANNA and our clients with access to its institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help STEINBERGANNA manage or administer our clients’ accounts, while others help STEINBERGANNA manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to STEINBERGANNA. Following is a more detailed description of Schwab’s support services: 13  Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that may not directly benefit you. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. We may have an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily 14  supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s services that benefit only us. We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to STEINBERGANNA as part of our evaluation of these broker-dealers. Aggregating Trades B. Commission costs per client may be lower on a particular trade if all clients in whose accounts the trade is to be made are executed at the same time. This is called aggregating trades. STEINBERGANNA does not aggregate trades. Trades are entered individually for each account. Directed Brokerage STEINBERGANNA allows clients to direct brokerage. “Directing” brokerage means choosing to maintain all or some of their assets with a broker-dealer that is not recommended by STEINBERGANNA. STEINBERGANNA may be unable to achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost clients’ money because without the ability to direct brokerage STEINBERGANNA may not be able to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. Not all investment advisers allow their clients to direct brokerage. ITEM 13: REVIEW OF ACCOUNTS All accounts will be managed on an ongoing basis, with reviews with the client on at least an annual basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. Clients will receive statements directly from their account custodian, as well as copies of all trade confirmations directly from their account custodian. Clients will also receive a bill itemizing the fees to be debited, including the formula used to calculate the fee, the amount of assets the fee is based, and the time period covered by the fee. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION A. Economic Benefit Provided by Third Parties for Advice Rendered to Client. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. [In some cases, a recipient of such payments is an affiliate of ours or another party which has some pecuniary, financial or other interests in us (or in which we have such an interest).] You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when 15  selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). B. Compensation to Non-Advisory Personnel for Client Referrals. (which In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, STEINBERGANNA provides cash or non-cash compensation directly or indirectly to unaffiliated persons for include client referrals). Such compensation testimonials or endorsements in higher costs to the referred client. In this regard, arrangements will not result STEINBERGANNA maintains a written agreement with each unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: • Whether or not the unaffiliated person is a current client of our firm, • A description of the cash or non-cash compensation provided directly or indirectly by our firm to the unaffiliated person in exchange for the referral, if applicable, and • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm’s relationship with such unaffiliated person. In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is paying solicitation fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. ITEM 15: CUSTODY STEINBERGANNA deducts fees from client accounts and by permitting clients to issue standing letters of authorization (“SLOAs”). SLOAs permit a client to issue one document that directs STEINBERGANNA to make distributions out of the client’s account(s). STEINBERGANNA does not have custody of client funds otherwise. Clients will receive statements directly from their account custodian, as well as copies of all trade confirmations directly from their account custodian. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. Each quarter, clients will receive a statement from their account custodian showing all transactions in their account, including the fee. Clients will also receive a bill itemizing the fees to be debited, including the formula used to calculate the fee, the amount of assets the fee is based, and the time period covered by the fee. The invoice will also state that the fee was not independently calculated by the custodian. We encourage clients to carefully review the statements and confirmations sent to them by their custodian, and to compare the information on your monthly report prepared by STEINBERGANNA against the information in the statements provided directly from their account custodian. Please alert us of any discrepancies. 16  ITEM 16: INVESTMENT DISCRETION When STEINBERGANNA is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You may receive at your request written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive monthly statements from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an investment management agreement that outlines the responsibilities of both the client and STEINBERGANNA. ITEM 17: VOTING CLIENT SECURITIES Copies of our Proxy Voting Policies are available upon request. From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. STEINBERGANNA will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. STEINBERGANNA will not give clients advice on how to vote proxies. ITEM 18: FINANCIAL INFORMATION STEINBERGANNA does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients. 17