STILES FINANCIAL SERVICES INCORPORATED

7505 Metro Blvd, Suite 510 Edina, MN 55439 (952) 988-0452 May 16, 2025 Form ADV 2A and 2Bs for Corporate Retirement Plan Consulting Services This Brochure provides information about the qualifications and business practices of Stiles Financial Services Incorporated (SFSI). If you have any questions about the contents of this Brochure, please contact us at info@stilesfinancial.com or 952-988- 0452. 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. Additional information about SFSI is also available on the SEC’s website at www.adviserinfo.sec.gov. To access this information, you can make an inquiry using our name or our CRD number, which is 117023. Registration of an Investment Adviser does not imply any level of skill or training. i  Item 2 – Material Changes The material changes in this brochure from the last annual updating amendment of March 19, 2025, for Stiles Financial Services (SFSI) are described below. Material changes relate to Stiles Financial Services’ policies, practices, or conflicts of interests. • The firm has removed Brent Atherton. (Cover page) SFSI will provide our clients with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochures may be requested by contacting us at 952-988-0452 or info@stilesfinancial.com. ii  Item 3 - Table of Contents Item 1 – Cover Page ................................................................................................................................................... Item 2 – Material Changes ................................................................................................................................... ii Item 3 - Table of Contents ................................................................................................................................... iii Item 4 – Advisory Business ................................................................................................................................. 1 Item 5 – Fees and Compensation ...................................................................................................................... 2 Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................... 4 Item 7 – Types of Clients ...................................................................................................................................... 5 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .............................................. 5 Item 9 – Disciplinary Information .................................................................................................................... 6 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 6 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................................................................ 7 Item 12 – Brokerage Practices ........................................................................................................................... 8 Item 13 – Review of Accounts ............................................................................................................................ 8 Item 14 – Client Referrals and Other Compensation ................................................................................. 8 Item 15 – Custody ................................................................................................................................................... 9 Item 16 – Investment Discretion ....................................................................................................................... 9 Item 17 – Voting Client Securities ................................................................................................................... 10 Item 18 – Financial Information ...................................................................................................................... 10 Biography Supplement – Form ADV Part 2B for Susan M. Stiles, born 1959 ................................. 11 Biography Supplement – Form ADV Part 2B for Paul E. Tichy, born 1961 .................................... 13 Biography Supplement – Form ADV Part 2B for Kristine E. Iten, born 1984 ................................ 15 iii  Biography Supplement – Form ADV Part 2B for Mark R. Gierach, born 1976 .............................. 17 Biography Supplement – Form ADV Part 2B for John R. Stone, born 1964 .................................... 19 Brochure Supplement – Privacy Policy and Practices of Stiles Financial ....................................... 20 iv  Item 4 – Advisory Business SFSI, established in 2000, is wholly owned and managed by Susan M. Stiles and has $30,307,226.45of ERISA Section 3(38) contracts and $769,714,543.52of ERISA Section 3(21) contracts as assets under advisement as of December 30, 2024. SFSI provides (i) Corporate Retirement Plan Consulting Services for defined contribution and defined benefit plans, both qualified and non-qualified and (ii) prepares and delivers individual Financial Plan Consulting Services. As of December 31, 2024, SFSI has $439,250,499 assets under management in our Portfolio Management advisory service offered through SFSI’s wrap program. Please reference the Brochures specific to individual financial planning and our SFSI wrap program for additional information on those services. Corporate Retirement Plan Consulting Services SFSI’s Corporate Retirement Plan Consulting Services provide fiduciary consulting, investment monitoring and Plan oversight through the delivery of a process-driven implementation of fiduciary and industry best practices for the Plan Sponsor. Typically, this is accomplished through the investment or benefits committee and or the trustee(s). These services often include: • Performance monitoring, analysis and benchmarking, • Investment screening, reporting and asset class review, • Extensive fee analysis, disclosure, negotiating and benchmarking, • Plan benchmarking, • Vendor search including conversion services, • Vendor service negotiation, • Guidance and fiduciary education on formalization of the investment committee and implementation of an investment policy statement, • Participant education services, along with development and monitoring of risk- based asset class managed strategy portfolios and, in some cases, with age banded glide paths. 1  Ongoing services will generally include a self-assessment of plan operations review, 404(c) compliance review, fiduciary audit file annual checklist and implementation and documentation of industry best practices and procedures. Participant services can include group-based education seminars and one on one personalized meetings in person, over the phone or through webinars. SFSI will generally accept fiduciary responsibility either under ERISA 3(21) or 3(38). SFSI will often coordinate with other professionals including attorneys, actuaries, accountants, and plan vendors. A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. SFSI does not participate in a wrap fee program for its Corporate Retirement Plan Consulting Services. SFSI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SFSI from properly servicing the client account, or if the restrictions would require SFSI to deviate from its standard suite of services, SFSI reserves the right to end the relationship. Item 5 – Fees and Compensation Corporate Retirement Plan Consulting Services There are two distinct ways to engage SFSI for Corporate Retirement Plan Consulting; (i) through an ongoing regular fiduciary advisory and consulting engagement and/or (ii) for project-related services. Examples of project-related work might include requests for proposal (RFP) vendor and advisor searches, Plan conversion quarterbacking to a new platform, fund menu analysis and redesign, fee benchmarking and restructuring including vendor renegotiation, Plan design consultation and new Plan startup planning strategy and guidance, and employee financial planning workshops and seminars. Generally, the 2  Corporate Retirement Plan Consulting fee is established by considering the size of the plan in assets and the number of participants, asset flow, the number of company plans, the complexity and breadth of the services being rendered and the extent of the engagement and required services. In addition, fees can vary based on the extent and level of SFSI’s fiduciary status in relation to the Plan under ERISA 3(21) and 3(38). As full compensation for its services, SFSI receives a negotiated fee, which may be based on a percentage of assets under advisory management, a fixed fee, a hybrid fee that includes a portion based on percentage of assets under management and a portion that is a flat fee, and under specific circumstances an hourly rate. The maximum fee Stiles Financial will charge is a flat fee of 1.15% of the plan’s assets under management. Fees can be paid by the Plan Sponsor, the Plan or a combination. The specific manner in which fees are charged by SFSI is established in a client’s written agreement with SFSI. Generally, Retirement Plan Consulting fees are billed on a quarterly basis in advance and in some circumstances in arrears each calendar quarter, as specified by agreement. SFSI’s fees are separate and distinct from all other fees that may be charged to operate and administer a Plan. Examples of other fees that Plans may incur custodial fees, trustee fees, recordkeeping and operational fees charged by the vendor and third-party administrative fees, legal fees, audit fees, and investment management fees. All operational and administrative fees are completely separate from and in addition to SFSI’s advisory and consulting fee. In some cases, the Plan Sponsor pays the fees directly to the service provider which may include SFSI. In other cases, the Plan pays the provider fees from Plan assets which essentially means the participants bear the cost of maintaining the Plan. In some cases, fees are paid utilizing a combination of both approaches. Part of SFSI’s consulting services is to educate the Plan Sponsor on the fees incurred, disclose the fees and help determine the reasonableness of the fees by conducting thoughtful discussion around how the fees should be paid. For ongoing engagements, fees are typically charged quarterly in advance on an ongoing basis. For one-time projects, 50% of the fee is charged up-front. This upfront fee is refundable 3  only up to the unearned services provided by SFSI. If the project is cancelled prior to completion, the client will be issued a refund of unearned fees within 30 days of cancellation. The remainder of the fee is due upon completion of the project. The maximum dollar amount charged is a total of $100,000. Additionally, a fee ranging from $200 to $500 per hour can be charged for special activities and projects. All fees are determined in advance and prior to signing the agreement. In no event will SFSI charge fees of $1,200 or more, six months or more, in advance. The agreement continues until it is terminated by either party by giving written notice to the other, which can be received in email form. SFSI prepares client-specific bills following the terms in the signed agreement and mails and or emails the bill directly to the client for payment. Advisory fees paid in advance would be pro-rated and refunded to the client for unearned services within 60 days, as outlined in the advisory agreement. Item 6 – Performance-Based Fees and Side-By-Side Management SFSI does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or side-by-side management fees (where competing fee arrangements may create a conflict in the advisory services offered to clients). 4  Item 7 – Types of Clients SFSI offers retirement plan consulting to defined contribution and defined benefit plans, both qualified and non-qualified. In this arrangement, the client is the Plan Sponsor and the Plan. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss SFSI provides retirement plan investment committees and plan fiduciaries guidance and advice on the selection of the investment fund menu options available to employee plan participants. SFSI delivers insight into investment principles and practices that strives to be educational and informative, considering market and performance fluctuations. An appropriate plan menu will offer investment options that will meet the different time frames, risk profiles, and goals of a company’s employee base. SFSI’s investment analysis applies fundamental analytics with a qualitative overlay that encompasses diversification, asset allocation, and risk management. SFSI utilizes a combination of technology, research, and experience, to search the universe of available managers, mutual funds, collective trusts, investments and securities considering areas such as: • Overall returns, return consistency, expected returns and risk-adjusted returns • Peer group comparisons and manager history, including investment objectives, philosophy, guidelines and expense ratios • Index and benchmark performance standards A plan menu offering considers sectors relative to benchmarks and industries. Investing in securities involves risk of loss that Plans must understand and be prepared to bear. Recommended investment strategies that are offered through the plan menu accommodate investor’s various time frames, goals, and risk tolerance levels. Securities recommended for these plans will be made up of pooled investments, also known as Mutual Funds, and collective Investment Trusts. Within these funds, assets can range from money market funds, bond funds, equity funds, commodity funds, and stable value funds. Long-term investing is designed to capture market rates of both return and risk. Due to its 5  nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to the client’s evaluation of SFSI or the integrity of the firm’s management. SFSI has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Neither SFSI nor its representatives are registered as, or have pending applications to become, a broker/dealer, Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. SFSI employees that are properly insurance licensed may sell insurance products to clients to execute an overall financial plan. Some of the products may pay a commission that will be disclosed and paid to SFSI. If an insurance product carrier offers a fee-based product alternative, SFSI will generally recommend such a product that will fall under the umbrella of the wrap fee program. Clients are under no obligation to purchase insurance products through SFSI. Insurance products do not fall under the asset-based management fee or the program fee. SFSI may direct clients to third-party investment advisers and will be compensated via a fee share from the advisers to which it directs those clients and thus any conflict of interest is mitigated. SFSI will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. 6  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading SFSI has adopted a Code of Ethics for all employees describing its high standard of business conduct, and our fiduciary duty to clients. SFSI acknowledges the fiduciary duty that is our responsibility according to both the Advisers Act, as well as the more recent DOL Fiduciary Rule. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at SFSI must acknowledge the terms of the Code of Ethics annually, or as amended. SFSI anticipates that accounts SFSI has advisement authority over, may hold positions purchased by SFSI or recommended by SFSI in which SFSI clients or employees, directly or indirectly, have a position of interest. SFSI employees are required to follow SFSI’s Code of Ethics. Subject to satisfying this policy and applicable laws, employees of SFSI may trade for their own accounts in securities which are recommended to SFSI clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of advisory employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interests of clients. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a Plan or client in a security held by an employee. Employee trading is monitored to reasonably prevent conflicts of interest between SFSI and its clients. Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting us at 952-988-0452 or info@stilesfinancial.com. 7  Item 12 – Brokerage Practices A discussion of Brokerage Practices is not relevant to SFSI’s Corporate Retirement Plan Consulting Services. A few examples of SFSI’s responsibilities regarding brokerage practices is as follows. We would discuss with the plan sponsor client if offering a brokerage account option to participants is appropriate for the overall strategy of the plan. Do the employees understand the risks they take by having those accounts? Is it a workforce who has the sophistication and understanding of how to navigate and manage a self-directed brokerage account? Is the platform reasonably priced? Item 13 – Review of Accounts For Corporate Retirement Plan Consulting Services, SFSI employs a best-practices fiduciary process in developing and presenting Plan reviews that are delivered quarterly, semi- annually or annually. SFSI’s fiduciary plan reviews follow a standardized format that is outlined in the agreement entered with the Plan Sponsor. These review reports include thorough investment analysis and monitoring, fee disclosure and benchmarking, economic and financial market commentary, and an overview of plan statistics, data, and information regarding management of the Plan. These review reports are presented to the Retirement Plan Committee representing the Plan Sponsor. SFSI follows a fiduciary best practices model in developing and presenting formal Plan reviews. Item 14 – Client Referrals and Other Compensation SFSI may, via written arrangement, retain third parties to act as promoters for SFSI’s investment management services. All compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. SFSI will ensure each promoter is properly registered in all appropriate jurisdictions, if required. All such referral activities will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, where applicable. SFSI receives marketing assistance from some vendors. This creates a conflict because 8  occasionally vendors will contribute financially to offset certain costs associated with some marketing activities. This conflict is mitigated because SFSI will always place the interests of clients ahead of its own or any IAR’s interests. Item 15 – Custody Investment advisers are deemed to have custody if they hold, directly or indirectly, client funds or securities, or have any authority to obtain possession of them. Qualified custodians are banks, trust companies, and registered broker-dealers which maintain client funds and securities in separate accounts for each client under that client’s name, or in accounts that contain only client funds and securities under the name of the investment adviser as agent or trustee for the clients. SFSI will not have custody nor act as a trustee of client funds or securities. For Corporate Retirement Plan Consulting, SFSI does not have custody but develops Plan or client reports and periodic reviews from the information provided by custodians and/or broker-dealers. SFSI urges all clients to carefully and regularly review official custodial records and statements. Item 16 – Investment Discretion SFSI contractually receives discretionary authority. With discretionary authority, SFSI will have authorization to execute investment decisions without prior approval from the Plan. This is known as a Section 3(38) investment manager. Alternatively, SFSI may be contracted in a co-fiduciary status where the Plan Sponsor/Trustee retains ultimate decision-making authority for the investments in a Plan and may accept or reject the recommendations provided by SFSI. This is known as a Section 3(21) investment manager. In both cases, an investment policy statement is generally executed and approved by the Retirement Plan Benefits Committee and provided to SFSI. 9  Item 17 – Voting Client Securities SFSI does not vote proxies. Clients will receive proxies directly from the issuer of the security or the custodian and should direct all proxy questions to the issuer of the security. Item 18 – Financial Information Registered investment advisers are required in this Item to provide the client with certain financial information or disclosures about their respective Firm’s financial condition. SFSI has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. SFSI has no debt. 10  Biography Supplement – Form ADV Part 2B for Susan M. Stiles, born 1959 Education and Professional Designations Susan M. Stiles graduated from Cornell University, Johnson School of Management with a MBA in Finance and Accounting in 1991 and from Cornell University, School of Hotel Administration with a BS in 1981. Ms. Stiles attained her CFP® (Certified Financial Planner) designation in 1997. This is a certification awarded by the Certified Financial Plan Board of Standards. To earn the CFP® certification, candidates must: (1) have an associate degree (or higher) from an accredited college or university; (2) have at least three years of full-time personal financial planning experience, and (3) must complete a CFP® board registered program. To maintain the designation, 30 hours of continuing education are required every two years including 2 hours of code of ethics education. Ms. Stiles attained her Chartered Financial Consultant™ (ChFC®) designation in July 2007. This designation is awarded by The American College and requires three years of full-time business experience within the preceding five years and the completion of nine courses (that are the equivalent of 27 semester credit hours) with a final closed-book exam for each course. 30 hours of continuing education are required every two years. Ms. Stiles earned the Accredited Investment Fiduciary™ (AIF®) in 2006. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point- based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Ms. Stiles earned the Certified Plan Fiduciary Advisor (CPFA) designation in 2017. This is a designation that is issued by the National Association of Plan Advisors. There are no prerequisites, but candidates must successfully complete a final proctored certification exam. There are 20 credits of continuing education required every two years. 11  Business Experience • Stiles Financial Services Incorporated as President since 2000. • Landmark Financial Advisors as a Partner from March 1999 to July 2000. • Symmetric Investments, Inc. as a Financial Advisor from April 1993 to March 1999. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Ms. Stiles is licensed insurance agent with SFSI. Additional Compensation Susan M. Stiles is a licensed insurance agent. From time to time, she will offer clients advice or products from those activities. Clients should be aware that these services may pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. Stiles Financial Services, Inc. will always act in the best interest of the client, including the sale of commissionable products to advisory clients. There are circumstances where insurance products do not pay a commission but are under a fee-based wrap arrangement. Clients always have the right to decide whether or not to utilize the services of any representative of Stiles Financial Services, Inc. in such individual’s outside capacities. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions at the mailing address, email address or contact information provided on the cover of this Brochure. 12  Biography Supplement – Form ADV Part 2B for Paul E. Tichy, born 1961 Education and Professional Designations Paul E. Tichy graduated from DePaul University with an MBA in 1992 and from Northwestern University with a BA in 1984. Mr. Tichy earned the Accredited Investment Fiduciary™ (AIF®) in 11/2017. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Business Experience • Stiles Financial Services Incorporated as Investment Analyst and Portfolio Manager since May 2016. • Fisher Investments as a Regional Vice President from March 2015 to March 2016. • Anchor Bank as a Private Wealth Advisor from 2013 to 2014. • Merrill Lynch as a Financial Advisor from 2011 to 2013. • Cowen & Company in Institutional Sales from 2010 to March 2011. • RBC Capital Markets Corporation in Institutional Sales from 2009 to 2010. • Merrill Lynch in Institutional Sales from 2003 to 2009. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. 13  Other Business Activities Mr. Tichy is not engaged in any investment-related business or occupation (other than this advisory firm). Additional Compensation Other than salary, annual bonuses, or regular bonuses, Mr. Tichy does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through Stiles Financial Services, Inc. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Tichy’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 14  Biography Supplement – Form ADV Part 2B for Kristine E. Iten, born 1984 Education and Professional Designations Kristine E. Iten graduated from the University of Minnesota – Twin Cities with a BA in English in 2006. Ms. Iten attained her Accredited Asset Management Specialist (AAMS) designation in 2011. This designation is awarded by the College for Financial Planning and requires a series of 10 self-study modules, followed by a closed book proctored exam. There are 16 hours of continuing education required every two years to maintain the designation. Ms. Iten earned the Accredited Investment Fiduciary™ (AIF®) in 08/2020 This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Ms. Iten earned the Certified Plan Fiduciary Advisor (CPFA) designation in 10/2021. This is a designation that is issued by the National Association of Plan Advisors. There are no prerequisites, but candidates must successfully complete a final proctored certification exam. There are 20 credits of continuing education required every two years. Business Experience • Stiles Financial Services Incorporated as a Retirement Plan Specialist since September 2019. • Cornerstone Private Asset Trust Company as a Retirement Plan Specialist from June 2009 to September 2019. • Cornerstone Private Asset Trust Company as a Trust Operations Supervisor from June 2009 to September 2019. 15  Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Ms. Iten declared Bankruptcy in 2019. Other Business Activities Ms. Iten has no other reportable business activity. Additional Compensation Ms. Iten does not receive any additional compensation. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Ms. Iten’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 16  Biography Supplement – Form ADV Part 2B for Mark R. Gierach, born 1976 Education and Professional Designations Mark R. Gierach graduated from the University of Minnesota – Twin Cities with a BS in Business Management in 1998. Mr. Gierach earned his Masters in Business Administration (MBA) in Finance in 2006. Mr. Gierach earned the Accredited Investment Fiduciary™ (AIF®) in 2024. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Business Experience • Stiles Financial Services Incorporated as Investment Analyst and Portfolio Manager since July 2022. • Senior Portfolio Manager at Bremer Bank from May 2016 to May 2022. • Principal at Balanced Capital Management from August 2012 to May 2016. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Mr. Gierach has no other reportable business activity. Additional Compensation Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Gierach’s activities for Stiles 17  Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 18  Biography Supplement – Form ADV Part 2B for John R. Stone, born 1964 Education and Professional Designations John R. Stone graduated from the University of North Carolina, Chapel Hill, NC with a BA in Management and Society in 1987. Business Experience • Stiles Financial Services Incorporated as a Senior Wealth Manager as of March 2024. • US Bank as a Private Wealth Advisor from September 2021 to February 2024. • Bremer Bank as a Private Wealth Advisor from August 2018 to September 2021. • Ameriprise Financial as a Senior Financial Advisor / Manager from December 2012 to August 2018. • Moors & Cabot Investments as a Wealth Advisor from March 2010 to December 2012. • Wakulla Bank as a Wealth Advisor from April 2005 to January 2010, Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Mr. Stone has no other reportable business activity. Additional Compensation Mr. Stone does not receive any additional compensation. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Stone’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 19  Brochure Supplement – Privacy Policy and Practices of Stiles Financial Investment Advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information. Protecting the privacy of the investor is important to us. This notice describes the practices and policies through which we maintain confidentiality and protect the security of your non-public personal information. Gathering Information In the course of providing services to you, we may collect “non-public personal information” about you. This may include information we receive from you on suitability questionnaires, subscription agreements or other forms, such as your name, address, social security number and birth date. We may also collect information about your investment transactions with us and others, as well as other account data. “Non-public personal information” is non-public information about you that we obtain in connection with providing a financial product or service to you, such as the information described in the above examples. Disclosing Information We do not disclose non-public personal information about you or any of our former clients to anyone, except as permitted by law. We are permitted by law to share any of the information we collect in the normal course of serving clients with companies that perform various services such as custodians and broker-dealers. These companies will use this information only for the services for which we hired them and as allowed by applicable law. Federal law allows you the right to limit the sharing of your non-personal information by opting out of the following: sharing for affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. Please notify us immediately if you choose to opt out of these types of sharing. Confidentiality and Security Procedures To protect your personal information, we permit access only by authorized personnel. We maintain physical, electronic and procedural safeguards that comply with federal standards to protect the confidentiality, integrity and security of your non-public personal information. We will continue to adhere to the privacy policies and practices in this notice even after your contract has been terminated. Questions For questions about our policy, or additional copies of this notice, please contact our office at (952) 988-0452 or contact Susan M. Stiles at info@stilesfinancial.com. 20 

7505 Metro Blvd, Suite 510 Edina, MN 55439 (952) 988-0452 May 16, 2025 Form ADV 2A and 2Bs for Individual Financial Plan Consulting This Brochure provides information about the qualifications and business practices of Stiles Financial Services Incorporated (SFSI). If you have any questions about the contents of this Brochure, please contact us at info@stilesfinancial.com or 952-988- 0452. 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. Additional information about SFSI is also available on the SEC’s website at www.adviserinfo.sec.gov. To access this information, you can make an inquiry using our name or our CRD number, which is 117023. Registration of an Investment Adviser does not imply any level of skill or training. 1  Item 2 – Material Changes The material changes in this brochure from the last annual updating amendment of March 19, 2025, for Stiles Financial Services (SFSI) are described below. Material changes relate to Stiles Financial Services’ policies, practices, or conflicts of interests. • The firm has removed Brent Atherton. (Cover Page) SFSI will provide our clients with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochures may be requested by contacting us at 952-988-0452 or info@stilesfinancial.com. 2  Item 3 -Table of Contents Item 2 – Material Changes ................................................................................................................................... 2 Item 3 -Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Business ................................................................................................................................. 5 Item 5 – Fees and Compensation ...................................................................................................................... 6 Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................... 8 Item 7 – Types of Clients ...................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .............................................. 9 Item 9 – Disciplinary Information .................................................................................................................... 9 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 9 Item 12 – Brokerage Practices ......................................................................................................................... 11 Item 13 – Review of Accounts .......................................................................................................................... 11 Item 14 – Client Referrals and Other Compensation ............................................................................... 11 Item 15 – Custody ................................................................................................................................................. 12 Item 16 – Investment Discretion ..................................................................................................................... 12 Item 17 – Voting Client Securities ................................................................................................................... 12 Item 18 – Financial Information ...................................................................................................................... 12 Item 19 – Marketing and Advertising ............................................................................................................ 13 Biography Supplement – Form ADV Part 2B for Susan M. Stiles, born 1959 ................................. 14 Biography Supplement – Form ADV Part 2B for Paul E. Tichy, born 1961 .................................... 16 Biography Supplement – Form ADV Part 2B for Kristine E. Iten, born 1984 ................................ 18 Biography Supplement – Form ADV Part 2B for Mark R. Gierach, born 1976 .............................. 20 3  Biography Supplement – Form ADV Part 2B for John R. Stone, born 1964 .................................... 22 4  Item 4 – Advisory Business SFSI, established in 2000, is wholly owned and managed by Susan M. Stiles. As of December 31, 2024, SFSI has $439,250,499 in assets under management in our Portfolio Management advisory service offered through SFSI’s wrap program. SFSI has $30,307,226.45of ERISA Section 3(38) contracts and $769,714,543.52of ERISA Section 3(21) contracts in assets under advisement as of December 30, 2024. SFSI provides (i) Corporate Retirement Plan Consulting Services for defined contribution and defined benefit plans, both qualified and non-qualified and (ii) prepares and delivers individual Financial Plan Consulting Services. Please reference the SFSI Wrap Brochure specific to individual portfolio management for additional information on that service offering. Individual Financial Plan Consulting SFSI provides tailored Financial Plan advisory and consulting services to meet the specific needs and requests of individual clients. Clients are not required to participate in our Wrap Fee Program to hire SFSI for individual financial plan services. Plans are developed by acquiring information concerning the client’s assets, liabilities, present and future foreseeable obligations, present and future income, the client’s desired financial goals, and the client’s tolerance of risk, along with any other data related to these areas of a client’s financial profile. Development of a comprehensive financial plan may include: • Net worth statements, • Budgeting, • Financial goal setting and projections, • Asset protection implementation and risk management, • College planning, • Wealth accumulation • Retirement planning including gap analysis, accumulation, and income replacement strategies, • Investment analysis and allocation, 5  • Tax incentive concepts and • Estate planning concerns and strategies. Portfolio Management Client may elect to implement financial plans through SFSI’s Wrap Program, which provides continuous investment advice, personalized to the individual needs of each client. Wrap fee programs are arrangements in which clients receive investment advisory services, including portfolio management and investment advice) as well as execution of client transactions for an asset-based fee schedule disclosed in the Wrap Program ADV. Complete information about SFSI’s Wrap Program is included in a separate Form ADV Wrap Brochure. Item 5 – Fees and Compensation Individual Financial Plan Consulting A base fee of $3,000 is generally the minimum fee charged to develop a comprehensive financial plan (the “Plan”). Generally, an annual maintenance update does not incur and additional charge unless it results in a complete overhaul of the Financial Plan and the fee arrangement will be discussed and agreed upon with the client in advance. Financial planning fees are typically a fixed amount but may be based on an hourly fee. This fee can increase depending on the complexity of the Plan being developed. The complexity of a Plan is determined by the type of Plan the client requests. Portfolio review fees for non-managed and outside investments can also be provided as a part of our financial planning services. These fees vary according to the number of reviews requested over a 12-month period and are agreed upon prior to signing an agreement. Number of Portfolio Reviews Minimum Fee 4 quarterly reviews $4,000/annually 2 semi-annual reviews $2,500/annually 1 annual review $2,000/annually 6  For Financial Plans, 50% of the fee is charged up-front. This upfront fee is refundable only up to the unearned services provided by SFSI and will be returned within 60 days. The remainder of the fee is due upon completion of the Plan. Investment advice or other consultation that is outside of the scope of a Financial Plan provided by SFSI and that is not part of the wrap fee program and not on a retainer is charged as a Project Fee. 50% of the fee is charged up front for the Project and is refundable for unearned work that will be returned within 60 days of the Project being cancelled. The remainder of the fee is due upon the completion of the Project. A Project can include how the client’s assets are currently allocated, how SFSI would allocate their assets, and a summary of our overall services to the client if they wish to hire us on retainer as part of our wrap fee program. A Project can also provide consultation and advice to a client on negotiating a severance package or accepting a job offer with a variety of compensation tiers and alternatives. A Project can also involve a family estate planning execution or beneficiary asset distribution. Depending on the complexity of the project, the maximum fee total charged can be up to $20,000. If the Project or Plan is cancelled prior to completion, the client will be issued a refund of unearned fees within 60 days. Most Plans are completed within 6 months of the engagement and all fees are agreed upon prior to signing an agreement. Project completion time is heavily dependent on the scope of the Project and will be discussed and determined at the time of engagement. When a client hires SFSI on retainer, they are charged a fee based on the Fee Schedule detailed above. These fees are charged in advance quarterly on an ongoing basis. Additionally, a fee for Project work or additional ad hoc Financial Planning ranging from $200 to $500 per hour can be charged for special activities and projects. This fee varies based on staff assignments and levels of expertise. If the client terminates the agreement prior to completion of the Plan, services provided through the termination date must be paid upon receipt of the invoice. The agreement continues until it is terminated by either party by giving written notice to the other, which can be received via email, in person, or by mail. SFSI prepares client specific bills following the terms in the signed agreement. These bills are then sent via mail or email directly to the client for payment. 7  SFSI does not accept cash or credit card payments and cannot deduct the bill from any type of client account. Portfolio Management Please review to the Form ADV Wrap Brochure for a complete review of the fees and appropriate conflict disclosures related to SFSI’s wrap program. Other Fees and Compensation Life, disability, and long-term care products recommended in the Financial Plan developed for clients of SFSI may be purchased through SFSI an employee that is properly insurance licensed. Some of these products may pay a commission that will be disclosed and paid to SFSI. This is separate from a fee paid by the client for the development of the Financial Plan. If an insurance product carrier offers a fee-based product alternative, SFSI will generally recommend such a product that is under the execution of the Wrap Fee Program. Clients are under no obligation to affect purchases or trades through the General Agent and/or Representative that has provided their Financial Plan and should understand the conflicts of interest as outlined in Item 10. Item 6 – Performance-Based Fees and Side-By-Side Management SFSI does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or side-by-side management fees (where competing fee arrangements may create a conflict in the advisory services offered to clients). Item 7 – Types of Clients SFSI provides individual financial planning, and portfolio management offered through SFSI’s wrap program, to individuals, families, trusts, estates, charitable organizations, foundations, and corporations. 8  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss SFSI provides individual financial planning clients with insight into investment principles and practices that are educational and informative, especially in volatile markets when performance can fluctuate dramatically. SFSI’s investment discipline is an analytical approach with a qualitative overlay that generally emphasizes diversification, asset allocation and risk management. Investing in securities involves risk of loss that clients must understand and be prepared to bear. Recommended investment strategies tend to center on long-term investing that will generally follow a buy and hold strategy, updated periodically to reflect changes in the client’s investment objectives, risk tolerance, and time horizon. However, any investment strategy approach will be specific to the client time horizon, risk assessment, goals and overall financial profile. SFSI approaches each client with a customized and personalized strategy and solution. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to the client’s evaluation of SFSI or the integrity of the Firm’s management. SFSI has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations In some situations, a brokerage relationship may be preferable or complement an advisory relationship, depending on specific client needs. Clients who have a Plan prepared by SFSI should note that they are under no obligation to establish an advisory wrap fee program account through SFSI. SFSI’s Portfolio Management advisory service is managed completely through SFSI’s wrap fee program, as described in SFSI’s Form ADV Wrap Brochure. SFSI employees that are properly insurance licensed may sell insurance products to clients to execute an overall financial plan. Some of the products may pay a commission that will be 9  disclosed and paid to SFSI. If an insurance product carrier offers a fee-based product alternative, SFSI will generally recommend such a product that is under the execution of the wrap fee program. Clients are under no obligation to purchase insurance products through SFSI. Insurance products do not fall under the asset-based management fee or the program fee. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading SFSI has adopted a Code of Ethics for all employees describing its high standard of business conduct, and our fiduciary duty to clients. SFSI acknowledges that fiduciary duty is our responsibility according to both the Advisers Act, as well as the more recent DOL Fiduciary Rule. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at SFSI must acknowledge the terms of the Code of Ethics annually, or as amended. SFSI anticipates that, in appropriate circumstances, it will cause accounts over which SFSI has advisement authority to effect and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which SFSI clients or employees, directly or indirectly, have a position of interest. SFSI employees are required to follow SFSI’s Code of Ethics. Subject to satisfying this policy and applicable laws, employees of SFSI may trade for their own accounts in securities which are recommended to SFSI clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of advisory employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interests of clients. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same 10  securities as clients, there is a possibility that employees might benefit from market activity by a Plan or client in a security held by an employee. Employee trading is monitored to reasonably prevent conflicts of interest between SFSI and its clients. SFSI will always document any transactions that are conflicts of interest. SFSI and its employees will not engage in trading that operates to the client's disadvantage when similar securities are being bought or sold. Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting us at 952-988-0452 or info@stilesfinancial.com. Item 12 – Brokerage Practices A discussion of Brokerage Practices is not relevant to SFSI’s Financial Planning services. SFSI is an independent RIA and is contracted with Fidelity Institutional to custody client investable assets that are managed through SFSI wrap program. As such, SFSI does not recommend a brokerage firm. Item 13 – Review of Accounts A discussion related to Review of Accounts is not relevant to SFSI’s Individual Financial Plan Consulting Services. Specific information related SFSI’s wrap program for Review of Accounts is provided in the Form ADV Wrap Brochure. Item 14 – Client Referrals and Other Compensation SFSI does not participate in any referral arrangements or accept revenue sharing with custodians or plan platform sponsors. SFSI receives marketing assistance from some vendors. This creates a conflict because occasionally vendors will contribute financially to offset certain costs associated with some marketing activities. This typically will happen when we sponsor educational forums that clients and prospects are invited to attend. This conflict is mitigated because SFSI will always 11  place the interests of clients ahead of its own or any IAR’s interests. Item 15 – Custody Investment advisers are deemed to have custody if they hold, directly or indirectly, client funds or securities, or have any authority to obtain possession of them. Qualified custodians are banks and registered broker-dealers which maintain client funds and securities in separate accounts for each client under that client’s name, or in accounts that contain only client funds and securities under the name of the investment adviser as agent or trustee for the clients. SFSI will not have custody of client funds or securities. For individual financial planning services, SFSI does not provide custody but develops client reports and/or periodic reviews from the information provided by custodians and/or broker-dealers. SFSI urges all clients to carefully and regularly review official custodial records and statements. Specific information related Custody and SFSI’s wrap program is provided in the Form ADV Wrap Brochure. Item 16 – Investment Discretion A discussion related to Investment Discretion is not relevant to SFSI’s Individual Financial Plan Consulting Services. SFSI’s wrap program provides Portfolio Management on a discretionary basis. This means that SFSI makes investment decisions on a day-to-day basis without consultation with the client. This includes deciding to buy or sell and the price per share. Item 17 – Voting Client Securities SFSI does not vote proxies. Item 18 – Financial Information Registered investment advisers are required in this Item to provide the client with certain 12  financial information or disclosures about their respective Firm’s financial condition. SFSI has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Item 19 – Marketing and Advertising SFSI may, via written arrangement, retain third parties to act as promoters for SFSI’s investment management services. All compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. SFSI will ensure each promoter is properly registered in all appropriate jurisdictions, if required. All such referral activities will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, where applicable. 13  Biography Supplement – Form ADV Part 2B for Susan M. Stiles, born 1959 Education and Professional Designations Susan M. Stiles graduated from Cornell University, Johnson School of Management with a MBA in Finance and Accounting in 1991 and from Cornell University, School of Hotel Administration with a BS in 1981. Ms. Stiles attained her CFP® (Certified Financial Planner) designation in 1997. This is a certification awarded by the Certified Financial Plan Board of Standards. To earn the CFP® certification, candidates must: (1) have an associate degree (or higher) from an accredited college or university; (2) have at least three years of full-time personal financial planning experience, and (3) must complete a CFP® board registered program. To maintain the designation, 30 hours of continuing education are required every two years including 2 hours of code of ethics education. Ms. Stiles attained her Chartered Financial Consultant™ (ChFC®) designation in July 2007. This designation is awarded by The American College and requires three years of full-time business experience within the preceding five years and the completion of nine courses (that are the equivalent of 27 semester credit hours) with a final closed-book exam for each course. 30 hours of continuing education are required every two years. Ms. Stiles earned the Accredited Investment Fiduciary™ (AIF®) in 2006. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point- based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Ms. Stiles earned the Certified Plan Fiduciary Advisor (CPFA) designation in 2017. This is a designation that is issued by the National Association of Plan Advisors. There are no prerequisites, but candidates must successfully complete a final proctored certification exam. There are 20 credits of continuing education required every two years. 14  Business Experience • Stiles Financial Services Incorporated as President since 2000. • Landmark Financial Advisors as a Partner from March 1999 to July 2000. • Symmetric Investments, Inc. as a Financial Advisor from April 1993 to March 1999. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Ms. Stiles is a licensed insurance agent with SFSI. Additional Compensation Susan M. Stiles is a licensed insurance agent. From time to time, she will offer clients advice or products from those activities. Clients should be aware that these services may pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. Stiles Financial Services, Inc. will always act in the best interest of the client, including the sale of commissionable products to advisory clients. There are circumstances where insurance products do not pay a commission but are under a fee-based wrap arrangement. Clients always have the right to decide whether or not to utilize the services of any representative of Stiles Financial Services, Inc. in such individual’s outside capacities. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions at the mailing address, email address or contact information provided on the cover of this Brochure. 15  Biography Supplement – Form ADV Part 2B for Paul E. Tichy, born 1961 Education and Professional Designations Paul E. Tichy graduated from DePaul University with a MBA in 1992 and from Northwestern University with a BA in 1984. Mr. Tichy earned the Accredited Investment Fiduciary™ (AIF®) in 11/2017. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Business Experience • Stiles Financial Services Incorporated as Investment Analyst and Portfolio Manager since May 2016. • Fisher Investments as a Regional Vice President from March 2015 to March 2016. • Anchor Bank as a Private Wealth Advisor from 2013 to 2014. • Merrill Lynch as a Financial Advisor from 2011 to 2013. • Cowen & Company in Institutional Sales from 2010 to March 2011. • RBC Capital Markets Corporation in Institutional Sales from 2009 to 2010. • Merrill Lynch in Institutional Sales from 2003 to 2009. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. 16  Other Business Activities Mr. Tichy is not engaged in any investment-related business or occupation (other than this advisory firm). Additional Compensation Other than salary, annual bonuses, or regular bonuses, Mr. Tichy does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through Stiles Financial Services, Inc. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Tichy’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 17  Biography Supplement – Form ADV Part 2B for Kristine E. Iten, born 1984 Education and Professional Designations Kristine E. Iten graduated from the University of Minnesota – Twin Cities with a BA in English in 2006. Ms. Iten attained her Accredited Asset Management Specialist (AAMS) designation in 2011. This designation is awarded by the College for Financial Planning and requires a series of 10 self-study modules, followed by a closed book proctored exam. There are 16 hours of continuing education required every two years to maintain the designation. Ms. Iten earned the Accredited Investment Fiduciary™ (AIF®) in 08/2020 This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Ms. Iten earned the Certified Plan Fiduciary Advisor (CPFA) designation in 10/2021. This is a designation that is issued by the National Association of Plan Advisors. There are no prerequisites, but candidates must successfully complete a final proctored certification exam. There are 20 credits of continuing education required every two years. Business Experience • Stiles Financial Services Incorporated a Retirement Plan Specialist since September 2019. • Cornerstone Private Asset Trust Company as a Retirement Plan Specialist from June 2009 to September 2019. • Cornerstone Private Asset Trust Company as a Trust Operations Supervisor from June 2009 to September 2019. 18  Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Ms. Iten declared Bankruptcy in 2019. Other Business Activities Ms. Iten has no other reportable business activity. Additional Compensation Ms. Iten does not receive any additional compensation. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Ms. Iten’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 19  Biography Supplement – Form ADV Part 2B for Mark R. Gierach, born 1976 Education and Professional Designations Mark R. Gierach graduated from the University of Minnesota – Twin Cities with a BS in Business Management in 1998. Mr. Gierach earned his Masters in Business Administration (MBA) in Finance in 2006. Mr. Gierach earned the Accredited Investment Fiduciary™ (AIF®) in 2024. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Business Experience • Stiles Financial Services Incorporated as Investment Analyst and Portfolio Manager since July 2022. • Senior Portfolio Manager at Bremer Bank from May 2016 to May 2022. • Principal at Balanced Capital Management from August 2012 to May 2016 . Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Mr. Gierach has no other reportable business activity. 20  Additional Compensation Other than salary, annual bonuses, or regular bonuses, Mr. Gierach does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through Stiles Financial Services, Inc. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Gierach’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 21  Biography Supplement – Form ADV Part 2B for John R. Stone, born 1964 Education and Professional Designations John R. Stone graduated from the University of North Carolina, Chapel Hill, NC with a BA in Management and Society in 1987. Business Experience • Stiles Financial Services Incorporated as a Senior Wealth Manager as of March 2024. • US Bank as a Private Wealth Advisor from September 2021 to February 2024. • Bremer Bank as a Private Wealth Advisor from August 2018 to September 2021. • Ameriprise Financial as a Senior Financial Advisor / Manager from December 2012 to August 2018. • Moors & Cabot Investments as a Wealth Advisor from March 2010 to December 2012. • Wakulla Bank as a Wealth Advisor from April 2005 to January 2010, Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Mr. Stone has no other reportable business activity. Additional Compensation Mr. Stone does not receive any additional compensation. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Stone’s activities for Stiles Financial Services Incorporated at the mailing address, email address or 22  contact information provided on the cover of this Brochure. 23  Brochure Supplement – Privacy Policy and Practices of Stiles Financial Investment Advisers are required by law to inform their clients of their policies regarding the privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information. Protecting the privacy of the investor is important to us. This notice describes the practices and policies through which we maintain confidentiality and protect the security of your non-public personal information. Gathering Information In the course of providing services to you, we may collect “non-public personal information” about you. This may include information we receive from you on suitability questionnaires, subscription agreements or other forms, such as your name, address, social security number and birth date. As well, we may collect information about your investment transactions with us and others, as well as other account data. “Non-public personal information” is non-public information about you that we obtain in connection with providing a financial product or service to you, such as the information described in the above examples. Disclosing Information We do not disclose non-public personal information about you or any of our former clients to anyone, except as permitted by law. We are permitted by law to share any of the information we collect in the normal course of serving clients with companies that perform various services such as custodians and broker-dealers. These companies will use this information only for the services for which we hired them and as allowed by applicable law. Federal law allows you the right to limit the sharing of your non-personal information by opting out of the following: sharing for affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. Please notify us immediately if you choose to opt out of these types of sharing. Confidentiality and Security Procedures To protect your personal information, we permit access only by authorized personnel. We maintain physical, electronic and procedural safeguards that comply with federal standards to protect the confidentiality, integrity and security of your non-public personal information. We will continue to adhere to the privacy policies and practices in this notice even after your contract has been terminated. Questions For questions about our policy, or additional copies of this notice, please contact our office at (952) 988-0452 or contact Susan M. Stiles at info@stilesfinancial.com. 24 

7505 Metro Blvd, Suite 510 Edina, MN 55439 (952) 988-0452 May 16, 2025 Form ADV Wrap Brochure 2A and 2Bs for Portfolio Investment Management This Brochure provides information about the qualifications and business practices of Stiles Financial Services Incorporated (SFSI). If you have any questions about the contents of this Brochure, please contact us at info@stilesfinancial.com or 952-988- 0452). 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. Additional information about SFSI is also available on the SEC’s website at www.adviserinfo.sec.gov. To access this information, you can make an inquiry using our name or our CRD number, which is 117023. Registration of an Investment Adviser does not imply any level of skill or training. 1  Item 2 – Material Changes The material changes in this brochure from the last annual updating amendment of March 19, 2025, for Stiles Financial Services (SFSI) are described below. Material changes relate to Stiles Financial Services’ policies, practices, or conflicts of interests. • The firm has removed Brent Atherton. (Cover page) SFSI will provide our clients with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochures may be requested by contacting us at 952-988-0452 or info@stilesfinancial.com. 2  Item 3 - Table of Contents Item 2 – Material Changes ...................................................................................................................................... 2 Item 3 - Table of Contents ....................................................................................................................................... 3 Item 4 – Services, Fees and Compensation ....................................................................................................... 4 Item 5 – Account Requirements and Types of Clients .................................................................................. 9 Item 6 – Portfolio Manager Selection and Evaluation ................................................................................. 10 Item 7 – Client Information Provided to Portfolio Managers .................................................................. 14 Item 8 – Client Contact with Portfolio Managers .......................................................................................... 14 Item 9 – Additional Information ......................................................................................................................... 15 Item 10 - Marketing and Advertising ............................................................................................................... 15 Item 11 - Other Financial Industry Activities or Affiliations ................................................................... 15 Item 12 - Code of Ethics ......................................................................................................................................... 15 Item 13 - Account Reviews ................................................................................................................................... 16 Item 14 - Account Statements and General Reports ................................................................................... 17 Item 15 - Custody ..................................................................................................................................................... 17 Item 16 - Trade Errors ........................................................................................................................................... 17 Item 17 - Referrals .................................................................................................................................................. 18 Item 18 - Receipt of Economic Benefit ............................................................................................................. 18 Item 19 - Additional Financial Information ................................................................................................... 18 Biography Supplement – Form ADV Part 2B for Susan M. Stiles, born 1959 ...................................... 19 Biography Supplement – Form ADV Part 2B for Paul E. Tichy, born 1961 ......................................... 21 Biography Supplement – Form ADV Part 2B for Kristine E. Iten, born 1984 ..................................... 23 Biography Supplement – Form ADV Part 2B for Mark R. Gierach, born 1976 ................................... 25 Biography Supplement – Form ADV Part 2B for John R. Stone, born 1964 ........................................ 27 Brochure Supplement – Privacy Policy and Practices of Stiles Financial ............................................ 28 3  Item 4 – Services, Fees and Compensation Stiles Financial Services Incorporated’s (“SFSI” or “Firm”) wrap program is offered through SFSI’s federally registered adviser under the Investment Advisors Act of 1940. SFSI, established in 2000, is wholly owned and managed by Susan M. Stiles. As of December 31, 2024, SFSI has $439,250,499 in assets under management in our Portfolio Management advisory service offered through SFSI’s wrap program. As of December 30, 2024, SFSI had $30,307,226.45of ERISA Section 3(38) contracts and $769,714,543.52of ERISA Section 3(21) contracts in assets under advisement through Corporate Retirement Plan Consulting Services provided to defined contribution and defined benefit plans, both qualified and non- qualified. Our Portfolio Management wrap program is described in greater detail in the narrative that follows. Please reference our additional Brochures for specific information on our other advisory offerings. Description of Our Wrap Fee Program Our wrap fee program (“Program”) provides clients with a platform to trade in a multitude of investment products for one a stated fee that is made up with a Portfolio Management Fee and Program Fee, both with break point schedules and structured as a percentage of assets under management. The fee is for portfolio management, design, structure and strategy as well as financial planning consultation. Transaction costs, and certain other administrative fees and technology and platform fees are offset by the Program Fee. There may be other de minimis fees deducted from your account by the custodian and SEC for certain positions that may be held in your portfolio. SFSI does not offer any other type of non-wrap non- discretionary agreement relationship. Wrap fee programs are any arrangements in which the clients receive investment advisory services (including portfolio management or advice on other investments) as well as execution of client transactions through a Portfolio Management Fee and a Program Fee. SFSI may contract with different custodians and will work with the client to determine the best fit for them. The client is required to open a new securities brokerage account and complete a new account agreement with the custodian as 4  well as fill out client suitability and risk profile forms for SFSI . To receive the services of the wrap program, the client is required to enter into a written agreement with SFSI which will contain the relevant terms and conditions of the advisory relationship (the “Agreement”). Once the SFSI wrap program relationship has been established, SFSI will work with the client to understand their individual liquidity and cash flow needs, time horizon and risk tolerance, investment objectives, as well as any other pertinent factors of their specific financial situation. With this information, SFSI designs and creates investment portfolio strategies to manage client investment assets and their financial affairs. SFSI manages client investment portfolios on a discretionary basis according to the terms of the advisory agreement. Discretion means that the client and SFSI have agreed that SFSI will select the identity and amount of securities to be bought or sold in their accounts without first consulting with the client. However, along with this authority, SFSI engages clients in continual, ongoing conversations and regular reviews to confirm that clients remain comfortable with the guidelines they have provided to manage their investment assets and understand investment changes, and the reasons behind changes in their portfolio investments. SFSI is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) to perform these services, and is expressly authorized to rely on such information provided by the client and their authorized professionals. SFSI may recommend its supervised employees in their individual capacities as insurance agents, however the client is under no obligation to act upon any such recommendation. The client is also advised that it remains the client’s responsibility to promptly notify SFSI of any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising SFSI’ previous recommendations and/or services. 5  Fees for Participation in the Program Fees for Portfolio Management are typically charged as an annual asset-based management fee and a separate Program Fee, which are billed quarterly and in advance. SFSI’s Program Fee is paid instead of brokerage commissions, transaction fees and other related costs and expenses that would normally be incurred by the client from the custodian. In addition, Program Fees offset other technology costs including portfolio reporting, and research tools incurred to manage our client portfolios. Program Fees are asset based charged at a uniform rate of .10% to .08% of assets under management and separate from the Portfolio Management Fee. This fee structure is intentionally designed to address any potential conflicts of interest and to segregate the costs associated with the overall management of the portfolio for the different services delivered. This fee offsets the costs associated with the utilization of custodians and technology tools where fees by these third parties would otherwise be charged to the client. The asset-based fees for the SFSI wrap program range according to the size, nature and complexity of the client relationship. In some situations, SFSI may accommodate clients in creating a custom fee schedule. Once a household AUM assets surpass a break point fee threshold, all the assets will be charged based on the lower fee. Fees may vary from the schedule below and final fees will be disclosed to clients within the client agreement: Household Assets under Management Annual Percent Fee $0 - $500,000 1.15% $500,001 - $1,000,000 0.95% $1,000,001 - $2,000,000 0.85% $2,000,001 - $5,000,000 0.75% $5,000,001 - $10,000,000 0.65% $10,000,000 and Over 0.55% 6  Description of Platform and Technology Fee This fee is charged to offset some of the costs of the trading, technology and custodial platform along with the technology and reporting suite of tools that SFSI uses and provides to our clients. SFSI charges a technology/platform fee based on the schedule below: Household Assets under Management Annual Percent Fee Up to $3,000,000 0.10% $3,000,001 and Over 0.08% The platform technology fee is charged quarterly and once the household AUM assets surpass the $3,000,001 threshold, then all the assets in the household will be charged at the lower fee rate. Prior to engaging us to provide Portfolio Management services, you are required to enter into a formal investment advisory agreement with us setting forth the wrap program fees to be charged to your account and other terms and conditions. Typically, SFSI charges all new relationships quarterly and in advance, based on the value of your account on the last day of the previous quarter. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Likewise, in the event that, an advisory contract is terminated, fees would be reimbursed in proportion to the number of days in the quarter for which you are not a client. Fee Comparison and Other Charges As referenced above, portions of the fees paid to SFSI are used to cover advisory services as well as custodial costs. Services provided through the Program may cost clients more or less than purchasing these services separately. Program fees may be higher or lower than other comparable programs. Wrap fee programs typically assume a certain amount of trading 7  activity in the client’s account, for example re-balancing the portfolio for the client’s individual development plan. Therefore, prolonged periods of holding cash positions, limited trading activity and inactivity may result in higher fees than if the account paid fees or commissions for each transaction separately. A one-time initial personal portfolio development fee may be charged for complex portfolios that could range up to $2,500.00. The fee is assessed on variables such as number of accounts, size of total household AUM, and level of special client-based guidelines or restrictions on investment positions for example, types of companies, sectors, or regions. Portfolios that generally may require more research beyond what our firm typically provides will be assessed a higher, one-time initial model development fee. The amount you pay for our wrap program and platform technology fees will depend, for example, on the services you receive and the amount of assets in your household. The more assets you have in the advisory accounts, the more you will pay us but will decline as a percentage of assets as your assets increase. The amount paid to our firm and your financial professional does not vary based on the type of investment we select on your behalf. The wrap program fee is paid instead of brokerage commissions, transaction fees and other related costs and expenses that would normally be incurred by the client from the custodian, as well as the reporting and research technology. The platform technology fee offsets some of the costs of the trading and other technology SFSI deploys to service client accounts. Both fees reduce the value of your account and will be deducted from your account. Neither one of these fees pay for any taxes that you may incur from your portfolio. Although transaction fees are usually included in the wrap program fee, sometimes you will pay an additional transaction fee for investments bought and sold outside our preferred custodian. Examples of other fees not included in the wrap program are SEC Section 31 fees, ADR fees, and fees to wire money. Some investments may also impose additional fees that will reduce the value of your investment over time, such as mutual funds and ETFs (exchange traded funds) and any other fees required by law. As part of our investment advisory services to you, we may invest in or you may transfer in mutual funds, exchange traded funds, or alternative investments. The fees 8  that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds, exchange traded funds or alternative investments, venture capital funds or private placements which are described in each fund's prospectus or disclosure. These fees can include a management fee and other fund expenses in the form of an expense ratio. SFSI also offers investment discretionary services on direct packaged products such as mutual funds, including 529 accounts and variable insurance products. A flat annual fee of 0.50% of the assets under management will be charged quarterly in arrears. For variable insurance products a flat annual fee of 0.75% of the assets under management will be charged quarterly in arrears. Fee Discretion SFSI, in its sole discretion, has the authority to negotiate a lesser fee amount based upon certain factors which could include related household accounts or a pre-existing client relationship. Fees are negotiable, so clients receiving the same service may be paying different fees. Fee Debit A client’s written agreement with SFSI establishes the specific way fees are charged. Clients authorize SFSI to directly debit fees from one or more of their investment accounts. Management fees are not prorated for each capital contribution and withdrawal made during the applicable calendar quarter. Item 5 – Account Requirements and Types of Clients SFSI offers its wrap program to individuals, families, trusts, estates, charitable organizations, foundations and corporations. 9  Item 6 – Portfolio Manager Selection and Evaluation Investment Portfolio Management SFSI consults with clients to develop an appropriate investment strategy that includes the client’s investment objectives, recommends investments, an appropriate asset allocation strategy, and provides proper education on the risk/return characteristics of available investments. Recommended investment strategies center on long-term investing that will generally follow a buy and hold strategy, updated periodically to reflect changes in the client’s or participant’s financial objectives and/or risk tolerance. Clients are responsible to promptly notify SFSI if there are changes in their financial situation that would change the manner of how we manage their portfolio, which would include placing any limitations on the overall portfolio management or individual holdings. Clients are entitled to place reasonable restrictions or mandates on the management of their accounts if SFSI determines, in its sole discretion, these restrictions would not materially impact the management strategy or performance or prove overly burdensome to SFSI’s management efforts. SFSI provides ongoing investment supervision, rebalancing your portfolio as needed and/or when there is a substantive deposit or withdrawal. We will initiate communication with you, at a minimum, annually to review and discuss any changes to your investment objectives, changes in market conditions and overall performance of your portfolios. You will receive ongoing and continuing information from SFSI on the economy, capital markets and other financial educational and planning topics pertinent to SFSI oversight of their client assets. You will also have the ability to meet with a SFSI representative at anytime, upon request. Investment Selection and Analysis SFSI recommends investments based upon sector, market capitalization, market style, domestic vs. international, allocation, proper balance with equity and fixed income for alignment with the investment policy directive created with the client. SFSI uses a variety of research tools and other relevant information available in the marketplace in determining 10  its in-house investment advice or recommendations. SFSI uses these research tools to invest in individual securities on our contracted custodial platforms for client accounts and will not unless expressly discussed with clients, transact on platforms outside of contracted platforms with SFSI. Performance Based Fees and Side by Side Management SFSI does not charge performance based or side by side management fees. Investment Strategies At SFSI, we manage the inherent risk in the financial markets through asset allocation and portfolio diversification. Our approach incorporates traditional asset classes, such as domestic and international equities including equities with companies that pay dividends and/or don’t pay dividends and both common and preferred stock of companies with varied market capitalization (small, medium and large). We also include corporate, government, agency, municipal, international and domestic bonds, as well as structured notes. Additionally, we may invest in closed end and exchange traded funds and alternative investments that may include private equity and venture capital. SFSI takes a diversified approach to portfolio management and each client has an investment strategy tailored to their individual financial objectives and risk tolerance. We recommend all types of securities, and do not recommend one particular type of security over another, as each client has various needs and tolerance for risk. Each type of security has its own unique set of risks associated with it. Risks can vary widely, even within the same type of investment. However, generally speaking, the greater the anticipated return of an investment, the higher the risk of loss associated with that investment. Risk of Loss There is no assurance that an investment will provide positive performance over any period of time. Past performance, while important, is no guarantee of future results and different 11  periods and market conditions may result in significantly different outcomes. Specific types of risk each client should understand, as they may be applicable to unique investment assets in a portfolio, include: • Market Risk: The price of a security may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Asset Allocation Risk: Asset allocation may have a more significant effect on account value when one of the heavily weighted asset classes is performing more poorly than the others. Diversification and strategic asset allocation do not assure profit or protect against loss in declining markets. • Concentrated Portfolio Risk: To the extent a portfolio has a large portion in a single security or several securities it bears more risk because it is not diversified. Changes in the value of significantly over-weighted security positions may have a much more substantial directional effect, either negative or positive, on the portfolio’s performance. Mutual funds or exchange-traded funds can spread some of the risk out, depending on their investment objective. • Emerging Foreign Market Risk: Investment in the securities of foreign issuers may 12  experience more rapid and extreme changes in value than funds with investments solely in securities of U.S. companies. The securities markets of many foreign countries are relatively small, with a limited number of companies representing a small number of industries. Additionally, foreign securities issuers may not be subject to the same degree of regulation as U.S. issuers. Reporting, accounting, and auditing standards of foreign countries differ, in some cases significantly, from U.S. standards. Also, nationalization, expropriation or confiscatory taxation, currency blockage, political change or diplomatic developments could adversely affect investments in a foreign country. • Fixed Income Risks, Including: interest rate risk, which is the chance that bond prices overall will decline because of rising interest rates; income risk, which is the chance that a strategy’s income will decline because of falling interest rates; credit risk, which is the chance that a bond issuer will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of the bond to decline; and call risk, which is the chance that during periods of falling interest rates, issuers of callable bonds may call (repay) securities with higher coupons or interest rates before their maturity dates. The investment would then lose any price appreciation above the bond’s call price and would be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the investment’s income. • Structured Note Risk: In the event that a structured product issuer becomes insolvent and defaults on their listed securities, investors will be considered as unsecured creditors and will have no preferential claims to any assets held by the issuer. Investors should pay close attention to the financial strength and credit worthiness of structured product issuers. Products such as derivative warrants and callable bull/bear contracts are leveraged and can change in value rapidly and may fall to zero resulting in a total loss of the initial investments. Structured securities are generally less liquid than conventional agency or corporate debt securities. As such, it may be relatively difficult to liquidate a structured security holding in a timely manner in 13  conjunction with withdrawal requests, margin calls or other market developments or factors. Additionally, the illiquid nature of these assets may make them harder to value. • Alternative Investment, Private Equity and Venture Capital Risk: Early stage investing can deliver higher than average returns, also has a risk of potential complete loss. This is considered a long-term type of investment. Investors need to be accredited or qualified depending on the specific investment. These types of investments are not liquid and investors need to be carefully qualified and vetted. Voting of Client Securities If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. We will not vote proxies on behalf of your advisory accounts. In most cases, you will receive proxy materials directly from the account custodian. SFSI will provide guidance and assistance in understanding proxy materials, upon request. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit, or if you are eligible to participate in class action settlements or litigation. We also do not initiate or participate in litigation to recover damages on your behalf. However, we will assist you in gathering data to participate in class action lawsuits, at your request. Item 7 – Client Information Provided to Portfolio Managers SFSI does not engage third-party portfolio managers. Item 8 – Client Contact with Portfolio Managers SFSI does not engage third-party portfolio managers. 14  Item 9 – Additional Information Disciplinary Information Registered Investment Advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to the evaluation of SFSI or the integrity of SFSI’ s management. SFSI has had no legal or disciplinary events to report. Item 10 - Marketing and Advertising SFSI may, via written arrangement, retain third parties to act as promoters for SFSI’s investment management services. All compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. SFSI will ensure each promoter is properly registered in all appropriate jurisdictions, if required. All such referral activities will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, where applicable. Item 11 - Other Financial Industry Activities or Affiliations SFSI employees that hold a current in force insurance license, may sell insurance products to clients to execute recommendations that may have been uncovered during a financial plan engagement. Some of the products may pay a commission that will be disclosed and paid to SFSI. If an insurance product carrier offers a fee-based product alternative, SFSI will generally recommend such a product that will fall under the umbrella of the wrap fee program. Clients are under no obligation to purchase insurance products through SFSI. Insurance products do not fall under the asset-based management fee or the program fee. Item 12 - Code of Ethics SFSI has adopted a Code of Ethics for all employees describing its high standard of business conduct, and our fiduciary duty to clients. SFSI acknowledges that fiduciary duty is our 15  responsibility according to both the Advisers Act, as well as the more recent DOL Fiduciary Rule. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised individuals at SFSI must acknowledge the terms of the Code of Ethics annually, or as amended. SFSI anticipates that accounts SFSI has advisement authority over, may hold positions purchased by SFSI or recommended by SFSI in which SFSI clients or employees, directly or indirectly, have a position of interest. SFSI employees are required to follow SFSI’s Code of Ethics. Subject to satisfying this policy and applicable laws, employees of SFSI may trade for their own accounts in securities which are recommended to SFSI clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of advisory employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interests of clients. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a Plan or client in a security held by an employee. Employee trading is monitored to reasonably prevent conflicts of interest between SFSI and its clients. Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting us at 952-988-0452 or info@stilesfinancial.com. Item 13 - Account Reviews SFSI provides ongoing investment supervision, rebalancing your portfolio as needed and/or when there is a substantive deposit or withdrawal. We communicate with you, at a minimum, annually to review and discuss any changes to your investment objectives, changes in market 16  conditions and overall performance of your portfolios. The process includes an investment- by-investment review for performance, appropriate allocation, alignment with objectives and risk tolerance, and total portfolio value. Factors within the quarter that may trigger additional review include unusual market activity or a change in the client’s investment objective or financial status. Item 14 - Account Statements and General Reports All clients of SFSI receive statements from their custodian at least quarterly. Client can also access account information through the custodian’s secure website. Item 15 - Custody Custody is defined as an investment advisory firm having access to client funds or securities. SFSI and its affiliates require that outside custodians hold all client assets. SFSI prohibits its supervised persons from acting as trustee for any client account. SFSI may deduct fees from client accounts for using SFSI’s portfolio management services. This deduction for SFSI fees is granted with a Withdrawal Power of Attorney, wherein the client provides written authority to the custodian to accept and act upon the instructions of SFSI to deduct fees each quarter. Clients are advised to review their fees as reported on their custodial statements and to respond immediately to SFSI with any questions. All clients of SFSI receive statements at least quarterly from your custodian, the qualified custodian that holds and maintains the client’s investment assets. Item 16 - Trade Errors Should a trading error occur in any client accounts, our policy is to restore the effected account to the position it should have been in had the trading error not occurred. Depending on the specific circumstance, our corrective actions may include canceling the trade, reimbursing the account, and/or adjusting the overall allocation. If a profit results from correcting the trade, you are not entitled to the profit as a net gain. If a loss results you will 17  not incur the loss. Item 17 - Referrals SFSI does not participate in any referral arrangements. Item 18 - Receipt of Economic Benefit SFSI receives marketing assistance from some vendors. This creates a conflict because occasionally vendors will contribute financially to offset certain costs associated with some marketing activities. This conflict is mitigated because SFSI will always place the interests of clients ahead of its own or any IAR’s interests. The custodians that we are contracted with offer some services that do not directly benefit you as the client and in some cases benefit only SFSI. Some examples of this are educational opportunities such as a conference where costs are discounted. Custodians may provide some legal and compliance consultation, marketing consulting and support, and referrals on practice management and business succession that may result in a fee SFSI may incur internally. Item 19 - Additional Financial Information Registered investment advisory firms are required to provide certain financial information or disclosures about SFSI’ financial condition. SFSI has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. SFSI carries no debt. 18  Biography Supplement – Form ADV Part 2B for Susan M. Stiles, born 1959 Education and Professional Designations Susan M. Stiles graduated from Cornell University, Johnson School of Management with a MBA in Finance and Accounting in 1991 and from Cornell University, School of Hotel Administration with a BS in 1981. Ms. Stiles attained her CFP® (Certified Financial Planner) designation in 1997. This is a certification awarded by the Certified Financial Plan Board of Standards. To earn the CFP® certification, candidates must: (1) have an associate degree (or higher) from an accredited college or university; (2) have at least three years of full-time personal financial planning experience, and (3) must complete a CFP® board registered program. To maintain the designation, 30 hours of continuing education are required every two years including 2 hours of code of ethics education. Ms. Stiles attained her Chartered Financial Consultant™ (ChFC®) designation in July 2007. This designation is awarded by The American College and requires three years of full-time business experience within the preceding five years and the completion of nine courses (that are the equivalent of 27 semester credit hours) with a final closed-book exam for each course. 30 hours of continuing education are required every two years. Ms. Stiles earned the Accredited Investment Fiduciary™ (AIF®) in 2006. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point- based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Ms. Stiles earned the Certified Plan Fiduciary Advisor (CPFA) designation in 2017. This is a designation that is issued by the National Association of Plan Advisors. There are no prerequisites, but candidates must successfully complete a final proctored certification exam. There are 20 credits of continuing education required every two years. 19  Business Experience • Stiles Financial Services Incorporated as President since 2000. • Landmark Financial Advisors as a Partner from March 1999 to July 2000. • Symmetric Investments, Inc. as a Financial Advisor from April 1993 to March 1999. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Ms. Stiles is a licensed insurance agent with SFSI. Additional Compensation Susan M. Stiles is a licensed insurance agent. From time to time, she will offer clients advice or products from those activities. Clients should be aware that these services may pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. Stiles Financial Services, Inc. always acts in the best interest of the client, including the sale of commissionable products to advisory clients. There are circumstances where insurance products do not pay a commission but are under a fee-based wrap arrangement. Clients always have the right to decide whether or not to utilize the services of any representative of Stiles Financial Services, Inc. in such an individual’s outside capacities. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions at the mailing address, email address or contact information provided on the cover of this Brochure. 20  Biography Supplement – Form ADV Part 2B for Paul E. Tichy, born 1961 Education and Professional Designations Paul E. Tichy graduated from DePaul University with a MBA in 1992 and from Northwestern University with a BA in 1984. Mr. Tichy earned the Accredited Investment Fiduciary™ (AIF®) in 11/2017. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Business Experience • Stiles Financial Services Incorporated as Investment Analyst and Portfolio Manager since May 2016. • Fisher Investments as a Regional Vice President from March 2015 to March 2016. • Anchor Bank as a Private Wealth Advisor from 2013 to 2014. • Merrill Lynch as a Financial Advisor from 2011 to 2013. • Cowen & Company in Institutional Sales from 2010 to March 2011. • RBC Capital Markets Corporation in Institutional Sales from 2009 to 2010. • Merrill Lynch in Institutional Sales from 2003 to 2009. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. 21  Other Business Activities Mr. Tichy is not engaged in any investment-related business or occupation (other than this advisory firm). Additional Compensation Other than salary, annual bonuses, or regular bonuses, Mr. Tichy does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through Stiles Financial Services, Inc. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Tichy’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 22  Biography Supplement – Form ADV Part 2B for Kristine E. Iten, born 1984 Education and Professional Designations Kristine E. Iten graduated from the University of Minnesota – Twin Cities with a BA in English in 2006. Ms. Iten attained her Accredited Asset Management Specialist (AAMS) designation in 2011. This designation is awarded by the College for Financial Planning and requires a series of 10 self-study modules, followed by a closed book proctored exam. There are 16 hours of continuing education required every two years to maintain the designation. Ms. Iten earned the Accredited Investment Fiduciary™ (AIF®) in 08/2020 This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Ms. Iten earned the Certified Plan Fiduciary Advisor (CPFA) designation in 10/2021. This is a designation that is issued by the National Association of Plan Advisors. There are no prerequisites, but candidates must successfully complete a final proctored certification exam. There are 20 credits of continuing education required every two years. Business Experience • Stiles Financial Services Incorporated a Retirement Plan Specialist since September 2019. • Cornerstone Private Asset Trust Company as a Retirement Plan Specialist from June 2009 to September 2019. • Cornerstone Private Asset Trust Company as a Trust Operations Supervisor from June 2009 to September 2019. 23  Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Ms. Iten declared Bankruptcy in 2019. Other Business Activities Ms. Iten has no other reportable business activity. Additional Compensation Ms. Iten does not receive any additional compensation. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Ms. Iten’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 24  Biography Supplement – Form ADV Part 2B for Mark R. Gierach, born 1976 Education and Professional Designations Mark R. Gierach graduated from the University of Minnesota – Twin Cities with a BS in Business Management in 1998. Mr. Gierach earned his Masters in Business Administration (MBA) in Finance in 2006. Mr. Gierach earned the Accredited Investment Fiduciary™ (AIF®) in 2024. This is a designation offered and recognized by the Center for Fiduciary Studies. Candidates must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development. Each candidate must complete an educational program and pass a final exam. To maintain this designation, six hours of continuing education are required per year. Business Experience • Stiles Financial Services Incorporated as Investment Analyst and Portfolio Manager since July 2022. • Senior Portfolio Manager at Bremer Bank from May 2016 to May 2022. • Principal at Balanced Capital Management from August 2012 to May 2016. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Mr. Gierach has no other reportable business activity. Additional Compensation Other than salary, annual bonuses, or regular bonuses, Mr. Gierach does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory 25  services through Stiles Financial Services, Inc. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Gierach’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 26  Biography Supplement – Form ADV Part 2B for John R. Stone, born 1964 Education and Professional Designations John R. Stone graduated from the University of North Carolina, Chapel Hill, NC with a BA in Management and Society in 1987. Business Experience • Stiles Financial Services Incorporated as a Senior Wealth Manager as of March 2024. • US Bank as a Private Wealth Advisor from September 2021 to February 2024. • Bremer Bank as a Private Wealth Advisor from August 2018 to September 2021. • Ameriprise Financial as a Senior Financial Advisor / Manager from December 2012 to August 2018. • Moors & Cabot Investments as a Wealth Advisor from March 2010 to December 2012. • Wakulla Bank as a Wealth Advisor from April 2005 to January 2010, Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Other Business Activities Mr. Stone has no other reportable business activity. Additional Compensation Mr. Stone does not receive any additional compensation. Supervision Ms. Stiles, as President and Chief Compliance Officer is responsible for the activities and operation of the Firm. She should be contacted directly with any questions about Mr. Stone’s activities for Stiles Financial Services Incorporated at the mailing address, email address or contact information provided on the cover of this Brochure. 27  Brochure Supplement – Privacy Policy and Practices of Stiles Financial Investment Advisers are required by law to inform their clients of their policies regarding the privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information. Protecting the privacy of the investor is important to us. This notice describes the practices and policies through which we maintain confidentiality and protect the security of your non-public personal information. Gathering Information In the course of providing services to you, we may collect “non-public personal information” about you. This may include information we receive from you on suitability questionnaires, subscription agreements or other forms, such as your name, address, social security number and birth date. Also, we may collect information about your investment transactions with us and others, as well as other account data. “Non-public personal information” is non-public information about you that we obtain in connection with providing a financial product or service to you, such as the information described in the above examples. Disclosing Information We do not disclose non-public personal information about you or any of our former clients to anyone, except as permitted by law. We are permitted by law to share any of the information we collect in the normal course of serving clients with companies that perform various services such as custodians and broker-dealers. These companies will use this information only for the services for which we hired them and as allowed by applicable law. Federal law allows you the right to limit the sharing of your non-personal information by opting out of the following: sharing for affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. Please notify us immediately if you choose to opt out of these types of sharing. Confidentiality and Security Procedures To protect your personal information, we permit access only by authorized personnel. We maintain physical, electronic and procedural safeguards that comply with federal standards to protect the confidentiality, integrity and security of your non-public personal information. We will continue to adhere to the privacy policies and practices in this notice even after your contract has been terminated. Questions For questions about our policy, or additional copies of this notice, please contact our office at (952) 988-0452 or contact Susan M. Stiles at info@stilesfinancial.com. 28