Stirlingshire Investments

Item 1: Cover Page Stirlingshire RIA LLC Firm Brochure - Form ADV Part 2A September 24, 2026 This brochure provides information about the qualifications and business practices of Stirlingshire RIA LLC. If you have any questions about the contents of this brochure, please contact us at (877) 600-7026 or by email at: info@stirlingshire.com. 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. Stirlingshire RIA LLC is registered with the SEC as an investment adviser. Registration does not imply a certain level of skill or training. Additional information about Stirlingshire RIA LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. 15 W. 38th St. #704 New York City, NY 10018 (877) 600-7026 info@stirlingshire.com www.stirlingshire.com 1  Item 2: Material Changes This section describes material changes made to this brochure since Stirlingshire RIA LLC (Stirlingshire) filed its Annual Updating Amendment on September 18, 2025. • • • • Item 5 (Fees and Compensation) has been updated to reflect the Firm’s Fee Schedule and the addition of fees paid to third parties. This item was also further updated to provide more details about third-party fees, which are paid by the client. Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) has been reorganized and updated to more fully explain the risks associated with the types of investments used to construct client portfolios. Item 10 (Other Financial Industry Activities and Affiliations) has been updated to reflect the addition of fees paid to third parties for referrals and BD affiliations under the Finalis referral program. This section was also updated to expand upon Stirlingshire’s relationship with its affiliated broker-dealer, and the different ways clients can conduct business with its dually-registered representatives. Item 14 (Client Referrals and Other Compensation) has been updated to reflect the addition of fees paid to a third party for referrals, under the Finalis referral program. Stirlingshire has also revised language throughout this Disclosure Brochure. We urge all clients to read this Disclosure Brochure in its entirety. 2  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ........................................................................................................................................................................ 2 Item 3: Table of Contents........................................................................................................................................................................ 3 Item 4: Advisory Business ........................................................................................................................................................................ 4 Item 5: Fees and Compensation ............................................................................................................................................................ 6 Item 6: Performance-Based Fees and Side-By-Side Management ............................................................................................ 9 Item 7: Types of Clients ......................................................................................................................................................................... 10 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................................................ 10 Item 9: Disciplinary Information...................................................................................................................................................... 15 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................. 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................... 16 Item 12: Brokerage Practices .............................................................................................................................................................. 17 Item 13: Review of Accounts ............................................................................................................................................................. 18 Item 14: Client Referrals and Other Compensation................................................................................................................. 19 Item 15: Custody ...................................................................................................................................................................................... 19 Item 16: Investment Discretion...........................................................................................................................................................20 Item 17: Voting Client Securities (Proxy Voting) ........................................................................................................................ 20 Item 18: Financial Information .......................................................................................................................................................... 20 3  Item 4: Advisory Business Stirlingshire RIA LLC is an investment adviser registered with the Securities Exchange Commission (“SEC”) since 2023. Throughout this Brochure, Stirlingshire RIA LLC will be called “Stirlingshire,” or “the firm,” “our,” “we,” or “us.” Stirlingshire RIA is a Delaware limited liability company and is a wholly owned subsidiary of Stirlingshire Investments Inc, a Delaware corporation. Stirlingshire’s principal office is in New York, New York with advisers located remotely in other locations in the United States. Discretionary Portfolio Management Services that information into the portfolio’s Stirlingshire provides portfolio management advisory services. These services include the employment of various methodologies for portfolio management advice and execution. These solutions are customized to each client and based on individual characteristics, such as the client’s age, risk tolerance, income, and current assets, among others. Stirlingshire’s investment advisory personnel oversee investment management on a discretionary basis, which means that you authorize us to buy and sell securities in your account without consulting with you first. Clients are encouraged to update their investment profile with any change in their objectives, risk tolerance, or other financial information, as investment factors recommendations. Advyzon Investment Management Stirlingshire makes a wide range of investment models available to its financial professionals by arrangement with Advyzon Investment Management (AIM), a registered investment advisor. Following authorization by the client to participate in the program, consideration of your investment objectives, and individual characteristics, Stirlingshire may elect to invest all or a portion of your portfolio using one of these model strategies. These model strategies are constructed using mutual funds, exchange-traded funds (ETFs), fixed-income securities, and/or equities. Stirlingshire remains responsible for determining the appropriateness of any model for its clients. Once a model is selected by Stirlingshire for its client, AIM will manage those assets in the selected model strategy on a discretionary basis without seeking prior permission from the client. AIM is not affiliated with Stirlingshire. Services Limited to Specific Types of Investments Stirlingshire generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. 4  Stirlingshire may recommend other securities as well to help diversify a portfolio when applicable and appropriate for a client’s portfolio. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We also have a fiduciary duty under the Investment Advisers Act of 1940, as amended, with respect to all client accounts. The way we make money creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Client tailored services and restrictions Stirlingshire provides portfolio management advisory services. Client accounts are invested according to the client’s individual objectives as described to their financial advisor. The client’s investment profile informs the portfolio strategies recommended by Stirlingshire. A client’s investment profile may also impose reasonable restrictions on investing in certain securities or types of securities. 5  Assets Under Management Stirlingshire has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $244,624,972.00 $0 June 30, 2026 Item 5: Fees and Compensation A. Management Fees Type Fee Portfolio Management Fees Assets Under Management (AUM) - Annual Rates: Asset Tier Annual Fee Rate First $250,000 2.00% $250,001 - $500,000 1.75% $500,001 - $1,000,000 1.50% $1,000,001 - $3,000,000 1.25% $3,000,001 - $5,000,000 1.00% $5,000,001 - $10,000,000 0.75% Over $10,000,000 0.50% Key Details: • Blended Calculation: Fees are calculated across all tiers based on total AUM • Monthly Billing: Billed monthly in arrears based on average daily balance Actual fees are documented in the Advisory Agreement between Stirlingshire and Client Stirlingshire’s portfolio management fees are negotiable up to 2.00% of assets under management as such fee is agreed upon by the adviser and client in relation to the type of account, assets, and number of accounts managed by Stirlingshire. 6  Stirlingshire uses an average of the daily balance in the client's account throughout the billing period to determine the market value of the assets on which the advisory fee is based. Clients may terminate the investment advisory agreement without penalty for a full refund of Stirlingshire's fees within five (5) business days of signing the agreement. Thereafter, either party may terminate the investment advisory contract immediately upon written notice. Additional fees in relation to trade or account activity assessed by the brokerage firm or custodian holding the client's accounts are not included in the portfolio management fee or the AIM model strategy fee (see below for more information). AIM Model Marketplace Fees Type Fee AIM Model Strategy Fee, applicable to assets invested in a model offered in the AIM model marketplace Between 20 and 100 basis points, dependent on the model selected, broken down as follows: AIM Access Fee for access to the model marketplace: 20 Basis Points Specific Model Strategy Fee: 0 – 80 Basis Points The specific model strategy fee is determined by the strategist that has developed the model and made it available in the AIM model marketplace. The AIM model strategy fee is the total of the AIM access fee and the specific model strategy fee and is applicable to the assets invested in a particular model. AIM uses the average daily balance in the client’s account throughout the billing period to determine market value of the assets on which the model strategy fee is based. B. Payment of Management Fees Portfolio management fees are paid in arrears and withdrawn monthly directly from each client's account as authorized by the client in their investment advisory contract. AIM model strategy fees are paid in arrears and withdrawn quarterly directly from each client’s account as authorized by the client in their investment advisory contract. Management fees are subject to change from time to time, upon notice to you. Upon your request, and at no charge, you may contact Stirlingshire to request information about the management fee charged to your account and how it is calculated. 7  C. Additional Fees and Expenses The portfolio management fee does not cover ▪ exchange fees, alternative trading system fees, required SEC fees or similar fees charged by third parties, including regulators and issuers ▪ ▪ brokerage account fees for services provided by Apex Fintech Solutions (“Apex Clearing Corporation,” “Apex Clearing,” or “Apex”) such as IRA administration, maintaining inactive accounts, transferring funds or securities to another firm via ACAT, wires, sending paper statements/confirmations, etc.; these fees will change from time to time and can be found at https://stirlingshire.com/disclosures/fee- schedule.pdf fees, expenses, and charges assessed by mutual funds and ETFs or by the managers or sponsors of funds, including internal fees, expenses and charges of the funds used in the portfolios and models ▪ any other charges imposed by law or otherwise agreed to relating to your account Clients are responsible for the payment of all third-party fees, which are separate and distinct from the fees and expenses charged by Stirlingshire. Please see Item 12 of this brochure for further discussion regarding brokerage practices. D. Prepayment of Fees Stirlingshire charges fees in arrears. It does not collect fees in advance. E. Outside Compensation for the Sales of Securities to Clients 1. Registered Representatives of SBD Certain individuals associated with Stirlingshire are also registered representatives of an affiliated Broker-Dealer, Stirlingshire BD LLC (SBD). In this role, they receive compensation including commissions for the sale of investment products to Stirlingshire clients. Individuals associated with Stirlingshire are not required to also be registered representatives of SBD. Clients may identify if an individual is also associated with SBD at FINRA BrokerCheck. Supervised persons receive compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds to Stirlingshire's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. We mitigate this conflict by supervising how dually registered representatives manage clients’ investments, and we disclose these conflicts in various disclosure documents provided to clients, including this Brochure. 8  2. AIM Model Strategies Stirlingshire may elect to invest a client’s assets in an AIM model strategy developed by Stirlingshire’s Chief Market Strategist and made available to clients through the AIM model marketplace. Stirlingshire’s model strategies are also available to individuals accessing the AIM model marketplace through other investment advisers. AIM model strategy fees collected by AIM on assets invested in a Stirlingshire model strategy are paid to Stirlingshire. Stirlingshire conveys 100% of this model strategy fee to its Chief Market Strategist. This presents a conflict of interest and gives Stirlingshire an incentive to recommend our model strategy over other strategies available in the AIM marketplace. 3. Option to use other broker dealers Clients have the option to purchase investment products that Stirlingshire recommends through other brokers or agents that are not affiliated with Stirlingshire. 4. Advisory Fees in Addition to Commissions or Markups Management fees and AIM model strategy fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. 5. Finalis Referral Program We have entered into an advisor referral agreement with Finalis Investment Advisory LLC (“Finalis”), an unaffiliated state-registered investment advisor. Under this agreement, Finalis refers individuals to Stirlingshire for potential registration as investment advisor representatives (IARs”) of our firm. We pay Finalis a referral fee equal to a percentage of the asset based advisory fees generated by those IARs. This referral fee does not increase the advisory fee you pay, however, the arrangement creates a conflict of interest because we and Finalis have a financial incentive for referred IARs to generate advisory business and to increase and retain assets under management. Item 6: Performance-Based Fees and Side-By-Side Management Stirlingshire does not accept performance-based fees or other fees based on a share of capital gains or capital appreciation of client assets. 9  Item 7: Types of Clients Stirlingshire provides advisory services to individuals, trusts, and entities. Stirlingshire does not require a minimum account size to use our services, however, investment adviser representatives may choose to impose account minimums in their independent practices. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Stirlingshire’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern Portfolio Theory, Quantitative Analysis and Technical analysis, or any combination of the methodologies listed or additional methods that are not listed here. Charting analysis searches for patterns in performance charts and uses them to help predict favorable conditions for buying, selling, or holding a security based on long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be assuming that past performance is indicative of future performance, which is oftentimes not the case. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying, selling, or holding securities. This method assumes that the markets react in cyclical patterns which, once identified, could be used to predict performance. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern Portfolio Theory seeks to maximize expected return for a given level of risk—or minimize risk for a given expected return—by selecting the right mix of assets. It assumes investors are risk averse, meaning they prefer lower risk for the same expected return and accept higher risk only when compensated by higher expected returns. A rational investor 10  therefore avoids any portfolio that is dominated by another with a better risk-return profile. The main risks of relying on this framework are unstable inputs (expected returns and correlations), misplaced confidence in diversification, and its mismatch with real market behavior, especially during periods of economic stress. Quantitative analysis deals with measurable factors such as the value of assets, the cost of capital, historical projections of sales, and so on. Investment strategies using quantitative models may perform differently than expected because of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis involves the analysis of past market data, primarily price and volume. This method attempts to predict future stock prices or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified, then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not consider new patterns that emerge over time. Other methods of analysis and may be deployed by adviser representatives or portfolio managers if they meet a client’s particular financial needs, risk profile, and overall investment strategy. Investing in securities involves a risk of loss, up to and including total loss of principal that you, as a client, should be prepared to bear. Investment Strategies Stirlingshire uses long-term trading, short-term trading, short sales, margin transactions and options trading. Short sales, margin transactions and options trading generally hold greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long-term trading is designed to capture market rates of both return and risk. Due to its 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. Short-term trading risks include liquidity, economic stability, and inflation, in addition to the long-term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby 11  triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Risks of Specific Securities Investment Company Risk is the risk that, when a client account is invested in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies' investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed. Alternative Strategy Mutual Funds invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense ratios than more traditional mutual funds. They also tend to be newer and have less track record or performance history. Exchange Traded Funds, or ETFs, invest in individual stocks and bonds that are subject to risks that include industry conditions, laws, governmental regulation, competition, technological developments, and national and international political circumstances. It is possible that these portfolios will lose money. The shorter the holding period one considers, the greater the probability of a loss over that holding period. ETFs are typically investment companies that are legally classified as open-end mutual funds or Unit Investment Trusts (UITs). ETFs differ from traditional mutual funds, in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares of other publicly traded companies. ETF shares may trade at a discount or premium to their net asset value. This difference between the bid price and the ask price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading volume and market liquidity and is generally lower if the ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market liquidity. Although many ETFs are registered as investment companies under the Investment Company Act of 1940, some ETFs, in particular those that invest in commodities, are not registered as investment companies. ETFs may be closed and liquidated at the discretion of the issuing company. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The values of equity securities fluctuate in response to specific situations for each company, 12  industry conditions and the general economic environments. Equities are subject to several risks such as market volatility, company-specific failures, macroeconomic shocks, inflation, liquidity constraints, political disruptions, and concentration risks. These risks are fundamental to stock ownership and cannot be fully mitigated through diversification. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both inflation issuers and counterparties. The risk of default on treasury protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. If you consider purchasing a variable annuity, you will receive a prospectus and should rely solely on the disclosure contained in the prospectus with respect to the terms and conditions of the variable annuity. You should also be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Investing in these funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices and the lack of liquidity and performance volatility. In addition, these funds are not required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Clients should be aware that these funds are not liquid as there is no secondary trading market available. At the absolute discretion of 13  the issuer of the fund, there may be certain repurchase offers made from time to time. However, there is no guarantee that clients will be able to redeem the fund during the repurchase offer. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is especially high because of the uncertainty involved at that stage of development. These types of funds carry a high probability of capital loss, are extremely illiquid, and face elevated exposure to governance, fraud, and compliance risk. Valuations can lack transparency, and high management fees and dilution risk can erode returns. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Manager Risk is the risk that poor security selection or focus on securities in a particular sector, category, or group of companies will cause a fund to underperform relevant benchmarks or other funds with a similar investment objective. Market Risk is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. Credit Risk is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. Legislative Risk is the risk that regulations or legislation implemented by the government could significantly alter the business prospects of one or more companies. Emerging Markets Risk is the risk that emerging markets may have unstable, even volatile, governments. Political unrest can cause serious consequences for the economy and investors. These markets often suffer from insufficient labor and raw materials, high inflation or deflation, unregulated markets, and unsound monetary policies. Interest Rate Risk is the risk that fixed income securities will decline in value because of an increase in interest rates (a bond or fixed income fund with a longer duration will be more sensitive to changes in interest rates than those with shorter durations). Tax Consequences: Liquidating assets may result in tax consequences that should be discussed with your tax advisor. 14  Past performance is not a guarantee of future results. Investing in securities involves a risk of loss up to and including total loss of principal that you, as a client, should be prepared to bear. Item 9: Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that are material to your evaluation of our advisory business or the integrity of our management. Stirlingshire has no such events to disclose. Item 10: Other Financial Industry Activities and Affiliations Stirlingshire is under common control with Stirlingshire BD LLC (“SBD”), a full-service introducing broker-dealer registered with FINRA and the SIPC. Stirlingshire RIA and Stirlingshire BD share office space, personnel, and resources. Many of our financial advisers are also registered representatives of SBD. Therefore, in such a case, representatives can offer both investment advisory and brokerage services. When acting as a registered representative of SBD, these representatives will charge commission on a per-transaction basis when implementing their advice for clients in accordance with the SBD Fee Schedule. Before engaging with a Stirlingshire representative, you should take time to consider the differences between an advisory relationship and a brokerage relationship to determine which type of service best serves your investment needs and goals. Speak to your representative to understand the different types of services available, and to determine which assets should be managed on an advisory basis, and which assets should be sold on a brokerage basis. Representatives who are dually registered may recommend an investment as part of your advisory relationship and charge an annual fee as described in this brochure and pursuant to your advisory agreement, or, if it is in your best interest, may make recommendations in their capacity as a brokerage representative that you purchase or sell securities in a brokerage account for which you will pay a commission. Although cost is always a consideration when determining if an investment is in your best interest, it is not the only factor. Certain of our investment advisor representatives are also registered representatives of Finalis Securities LLC, a FINRA registered broker-dealer. These individuals provide investment advisory services through Stirlingshire RIA, and may separately provide brokerage services through Finalis Securities LLC. All advisory client brokerage transactions for advisory services described in this brochure are required to be effected through our affiliated broker-dealer, Stirlingshire BD LLC, and are not carried or executed through Finalis Securities LLC. Ask your financial advisor if you have questions about the capacity in which they are acting in respect to any financial transaction, or contact us at info@stirlingshire.com. Stirlingshire RIA clients who purchase securities to be managed under an advisory 15  agreement are required to utilize the brokerage services of SBD to effect those securities transactions. Apex Clearing Corporation (“Apex”) provides trade execution and clearing services to SBD and acts as the qualified custodian for Stirlingshire RIA’s clients’ holdings. Stirlingshire Investments has entered into an agreement with Apex in which Apex accepted an equity warrant for 3% ownership of Stirlingshire rather than requiring upfront, ongoing clearing fees. This is a conflict of interest since it incentivizes Stirlingshire to conduct business with Apex rather than another broker dealer that may be better aligned to our clients' interests. SBD receives fees and other benefits from their role as an introducing broker-dealer, including the receipt of securities lending revenue, which creates a conflict of interest between the firm and the client. Upon account opening, Stirlingshire clients may choose to enroll in the Securities Lending Program through Apex. Clients can opt in or out of the program by contacting Stirlingshire at 877-600-7026 or info@stirlingshire.com. Stirlingshire and its representatives sometimes select investment strategies run by third- party investment managers. When clients utilize a Stirlingshire model strategy from the AIM Model Marketplace, clients will be charged 30 basis points per annum on funds invested in a Stirlingshire model strategy. Such fees are paid directly to Stirlingshire’s Chief Market Strategist as developer of the Stirlingshire models. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Stirlingshire has adopted a written Code of Ethics expressing its commitment to ethical conduct to comply with applicable securities laws including those relating to employees’ personal trading, insider trading, and restrictions/reporting requirements around giving and receiving gifts and entertainment. Stirlingshire’s Code of Ethics describes the firm’s fiduciary duties and responsibilities to clients and sets forth Stirlingshire’s practice of supervising the personal securities transactions of employees. Individuals associated with Stirlingshire may buy or sell securities for their personal accounts identical to or different from those recommended to clients of the adviser. Associated persons may buy or sell specific securities for their own accounts that are not purchased or sold for clients. Stirlingshire monitors the securities transactions of all associated persons and investigates any unusual patterns that it detects. From time to time, Stirlingshire advisers may buy or sell securities for themselves at or around the same time as clients. This practice could provide an opportunity for representatives of Stirlingshire to buy or sell securities before or after recommending securities to clients, resulting in representatives profiting from the recommendations they provide to clients. Such transactions create a conflict of interest; however, Stirlingshire will never engage in trading that disadvantages a client if representatives of Stirlingshire buy or sell securities at or around the same time as clients. Stirlingshire’s clients or prospective clients may obtain a copy of the firm’s Code of Ethics by contacting Stirlingshire at 877-600-7026 or info@stirlingshire.com. 16  Item 12: Brokerage Practices Stirlingshire clients who purchase securities in connection with an advisory agreement with us are required to utilize the brokerage services of our affiliate, Stirlingshire BD LLC (“SBD”), a member of FINRA and SIPC, which acts as an introducing broker-dealer effecting securities transactions for clients’ accounts for which Apex Clearing provides trade execution and clearing services. Apex Clearing is a broker-dealer, member of FINRA and SIPC. Not all investment adviser firms require the use of a particular broker/dealer. However, for operational and compliance purposes, we have made the decision to provide all asset management services through one brokerage and custodial platform. You are not required or obligated to utilize our services and therefore you are not required or obligated to open an account with SBD and Apex. However, if you do not want to use SBD or Apex, we are unable to provide our discretionary asset management services to you. Stirlingshire seeks the best overall execution of transactions for client accounts. Using an affiliated broker presents a conflict of interest, as it results in additional compensation for the firm. Stirlingshire instructs Apex to route orders for “best execution” which is the firm’s obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. “Best execution” means the best overall qualitative execution, not necessarily the lowest possible commission cost. Accordingly, the factors that Stirlingshire considers when selecting or recommending brokers are matters that directly benefit client accounts and are consistent with obtaining the best execution of transactions. These factors include speed of execution, price improvement, commission, quality of overall execution services, expertise, financial condition, and skill. Stirlingshire does not receive payment for order flow. 1. Research and Other Soft-Dollar Benefits Stirlingshire receives no research, product, or services other than execution from broker- dealers or custodians in connection with client securities transactions (“soft dollar benefits”). 2. Brokerage for Client Referrals Stirlingshire receives no referral fees from SBD or other third-party in exchange for referrals. In addition, Stirlingshire does not receive any compensation for referrals from any other third party. 3. Brokerage Fee Schedule Clients may find the SBD Brokerage Fee Schedule here: https://stirlingshire.com/disclosures/fee- schedule.pdf 4. Clients Directing Which Broker/Dealer/Custodian to Use Stirlingshire requires clients to use its affiliated broker-dealer, SBD, and its clearing firm, 17  Apex, to execute transactions. Not all advisers require clients to use a particular Broker- Dealer. 5. SBD Receives Compensation from its Clearing Firm Stirlingshire’s affiliated broker-dealer, SBD, receives compensation from Apex. SBD receives various brokerage-related compensation related to customer account balances and investments. SBD earns revenue from 12b-1 fees, interest on margin balances, lending securities in client accounts, and interest on cash sweep balances. Customers do not receive interest on cash sweep balances. Share lending programs benefit SBD but will only benefit clients to the extent that the revenue is shared with clients. SBD customers using margin could be exposed to more risk, and SBD may in turn make more money. This creates conflicts with your interests. These programs are more fully described in the related brokerage account opening documents. For discussion of these fees please also see Form CRS for SBD. 6. Aggregated (Block) Trading If Stirlingshire buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such a case, Stirlingshire would place an aggregate order with the broker on behalf of all such clients. There is no guarantee that client executions will be conducted in an aggregate manner. Item 13: Account Review All client accounts that contract for Stirlingshire’s advisory services provided on an ongoing basis are reviewed at least annually regarding clients stated investment objectives and risk tolerance. Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance) as reported by the client to Stirlingshire. Each client of Stirlingshire's advisory services provided on an ongoing basis will receive, at least quarterly, a report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian in the form of an account statement. 18  Item 14: Client Referrals and Other Compensation Promoters Stirlingshire compensates unaffiliated third parties for referrals. Compensation is paid pursuant to a written agreement, and appropriate disclosures are made in compliance with the SEC Marketing Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended, to the extent required by applicable law. If a client invests in an advisory program with Stirlingshire as the result of such a referral, the compensation paid to the third party typically consists of an ongoing cash payment stated as a percentage of Stirlingshire’s advisory fee or a one-time flat fee, but may include cash payments determined in other ways. For example, Stirlingshire has entered into an adviser referral agreement with Finalis Investment Advisory LLC, an unaffiliated investment adviser firm. Under this arrangement, Stirlingshire pays Finalis a referral fee equal to 10% of the asset-based advisory fees generated by accounts managed by adviser representatives who were referred to Stirlingshire by Finalis. Clients do not pay any additional fees because of this arrangement; the referral fee is paid by Stirlingshire from its advisory fees. However, this arrangement creates a conflict of interest because Stirlingshire and Finalis have a financial incentive for these accounts to be retained and assets under management to increase. Stirlingshire and its supervised persons occasionally receive additional compensation from product and event sponsors. Such compensation may not be tied to the sales of any products, and includes nominally valued gifts, an occasional meal or event ticket, or reimbursement for costs associated with attending education or training events. Item 15: Custody The qualified custodian that actually holds the assets of Stirlingshire's clients is Apex Clearing, a member of FINRA and SIPC. As a regulatory matter, Stirlingshire is deemed to have custody of client funds and securities because Stirlingshire is given the authority to have fees deducted directly from client accounts. Apex issues account statements at least quarterly to all clients. Stirlingshire sends clients electronic notifications that the statements are available online. Stirlingshire also notifies clients electronically when transaction confirmations are available. These statements and confirmations may be delivered via mail for an additional fee at the client’s request. Stirlingshire also provides clients with online reports and data relating to their accounts, transactions, and holdings. We urge clients to compare the account statements they receive from the qualified custodian with those they receive from Stirlingshire. Clients should notify the custodian and Stirlingshire of any discrepancy. 19  Item 16: Investment Discretion Stirlingshire generally provides discretionary investment advisory services to clients. The investment advisory contract established with each client sets forth the adviser’s discretionary authority for trading. This means that Stirlingshire generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, Stirlingshire’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to Stirlingshire). Item 17: Voting Client Securities (Proxy Voting) Stirlingshire does not have, and will not accept, the authority to vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in their portfolios. Proxies will be forwarded directly to clients’ mailing or email addresses by Apex Clearing. Stirlingshire does not advise or act for you in any legal proceedings, including class actions or bankruptcies, involving securities purchased for or held in your account. Clients may contact their Stirlingshire financial advisor, or email info@stirlingshire.com, with questions about a particular solicitation. Item 18: Financial Information Stirlingshire neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include additional financial information with this brochure. Neither Stirlingshire nor its management has any financial condition that is likely to reasonably impair our ability to meet contractual commitments to clients. 20