STONEBRIDGE FINANCIAL GROUP, LLC

Part 2A of Form ADV: Firm Brochure Form ADV, Part 2A, Item 1 Cover Page 602 North Front Street Wormleysburg, Pennsylvania 17043 26A East Roseville Road Lancaster, Pennsylvania 17601 Tel: (717) 736-7007 Fax: (717) 761-6127 August 2025 FORM ADV PART 2 FIRM BROCHURE This brochure provides information about the qualifications and business practices of Stonebridge Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at (717) 736-7007. 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 Stonebridge Financial Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Stonebridge Financial Group, LLC is 327529. Stonebridge Financial Group, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Form ADV, Part 2A, Item 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a brochure by contacting us at (717) 736-7007. Material Changes since the Last Update The following material changes have been made since the last update filed on May 6, 2025: • Item 5 – Fees and Compensation – Stonebridge Financial Group, LLC updated this section to identify an inherent conflict when SFG encourages rollovers and the assets under SFG’s management increases leading to an increase in revenue. SFG also updated this section to disclose that certain SFG personnel who provide company-sponsored retirement plan consulting services can receive a one-time bonus when they successfully refer individuals at client companies to become advisory wealth management clients of SFG. Finally, SFG updated disclosures indicating that SFG is affiliated with several other non-investment advisory businesses such as payroll and human resource solutions and insurance products, including Medicare plans and, on occasion, SFG personnel recommend these affiliated services to clients. • Item 14 – Client Referrals and Other Compensation – SFG updated disclosures regarding solicitor agreements with Collaborative Advisory Group and Stambaugh Ness Wealth Management under which SFG pays these parties a portion of the advisory fees collected from referred clients in exchange for these referrals from these parties. 2  Form ADV, Part 2A, Item 3 Table of Contents Advisory Business ...................................................................................... 4 Fees and Compensation ............................................................................ 5 Performance-Based Fees and Side-By-Side Management ..................... 8 Types of Clients .......................................................................................... 8 Methods of Analysis, Investment Strategies, and Risk of Loss ........... 8 Disciplinary Information .............................................................................. 11 Other Financial Industry Activities and Affiliations................................ 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................................................... 12 Brokerage Practices .................................................................................... 12 Review of Accounts .................................................................................... 15 Client Referrals and Other Compensation ............................................... 16 Custody ........................................................................................................ 16 Investment Discretion ................................................................................. 17 Voting Client Securities.............................................................................. 17 Financial Information ................................................................................... 17 Requirements for State-Registered Advisers .......................................... 18 3  Form ADV Part 2A, Item 4 Advisory Business Stonebridge Financial Group, LLC (hereinafter called “SFG”) is a Registered Investment Adviser based in Wormleysburg, Pennsylvania, and incorporated under the laws of the State of Pennsylvania. Stonebridge Financial Group, LLC registered as a Registered Investment Advisor in November 2023 with the Securities and Exchange Commission (“SEC”), under the rules and regulations of the US Investment Advisers Act of 1940, as amended (the "Advisers Act"). SFG is majority owned by Brian McCarver and Jonathan Freeman. SFG is registered with the SEC and subject to the rules and regulations of the Advisers Act. SFG provides investment advisory services, which may include, but are not limited to, the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification. Please note e-mail is an acceptable form of written notification for these purposes. SFG also provides financial planning consulting services including, but not limited to, risk assessment/management, investment planning, estate planning, financial organization, or financial decision making/negotiation. SFG provides investment advisory and other financial services through its Investment Advisory Representatives ("IAR") to accounts opened with SFG. Managed Accounts are available to individuals, high net worth individuals, charitable organizations, and corporations. SFG provides discretionary and non-discretionary investment advisory services to some of its clients through various managed account programs. SFG will assist clients in determining the suitability of the Managed Account Programs for the client. The IAR is compensated through a comprehensive single fee and the account may be assessed other charges associated with conducting a brokerage business. SFG and its IAR, as appropriate, will be responsible for the following: • Performing due diligence • Recommending strategic asset and style allocations • Providing research on investment product options, as needed • Providing client risk profile questionnaire • Obtaining investment advisory contract from client with required financial, risk tolerance, suitability and investment vehicle selection information for each new account • Performing client suitability check on account documentation, review the investment objectives and evaluate the investment vehicle selections • Providing Firm Brochure (this document) SFG may recommend a Wrap Fee Program for the client’s account(s). A “wrap fee program” for purposes of the SEC is a program under which investment advisory and brokerage execution services are provided for a single “wrapped” fee that is not based on the transactions in a client 4  account. Clients with Wrap Fee Program accounts will be provided with SFG’s Wrap Fee Brochure. There is no difference between how SFG manages wrap fee accounts and how SFG manages other accounts. Company-Sponsored Retirement Plan Consulting Services - Stonebridge Financial Group, LLC provides company-sponsored retirement plan consulting services (hereinafter called “retirement plan consulting services”). These services may include plan design, investment lineup selection and monitoring, plan administration support, education, co-fiduciary support, and benchmarking. We will meet with the client to discuss the major plan goals, identify key employees, evaluate employer contribution options, and analyze income tax considerations. SFG will assist with the development of an appropriate investment strategy that reflects the plan sponsor’s stated investment objectives for management of the plan. SFG will design an investment lineup that meets the plan sponsor’s goals and objectives and will monitor the investments for potential changes. To conduct certain retirement plan consulting services, SFG will utilize discretionary authority to install platforms, add or remove funds to the plan’s investment portfolio, amend the weightings of the fund components, move funds from the various models in use, etc. As of December 31, 2024, the firm has the following assets under management: Discretionary AUM of $1,689,661,086 and Non-Discretionary AUM of $141,632,193. Form ADV, Part 2A, Item 5 Fees and Compensation The following types of fees will be assessed: Asset Management – Fees are charged quarterly in advance and are based primarily on asset size and the level of complexity of the services provided. In individual cases, SFG has the sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on the share of capital gains or capital appreciation of the funds or any portion of the funds. Comparable services for lower fees may be available from other sources. Fees for the initial quarter will be prorated based upon the number of calendar days in the calendar quarter that the advisory agreement is in effect. Fees are based on the market value of the assets on the last business day of the previous quarter. Annual fees are a maximum of 2%. Consulting services are included in these fees for asset management services with the exception of unique circumstances that may require a separate agreement for financial planning services (description and fees are discussed below). If the situation warrants separate financial planning fees, it will be discussed upfront, and a separate agreement will be negotiated. Account Maintenance Fee – Each Asset Management account will be charged a management fee on a calendar quarterly basis, which will be billed in advance of each calendar quarter. Each nondiscretionary account where the client requests to have the nondiscretionary account integrate and/or feed into Stonebridge's Black Diamond software for performance reporting purposes will be charged a quarterly account maintenance fee of $25 per quarter. 5  Option Account Fee – An additional flat fee percentage, on top of the tiered or breakpoint fee, will be applied to the billable assets of accounts with options trading authorized. Option Account Fee ranges from 0.25% - 0.5%. Accounts With Margin – Certain client accounts may have margin; however, it is not Stonebridge Financial Group, LLC’s practice to trade on margin, therefore when advisory fees are calculated the firm uses the market value of client accounts. The market values of client accounts are derived from our custodian. Wrap Accounts – Wrap accounts are subject to the same fees and fee schedule listed above as non-wrap accounts. Terms – As authorized in the client agreement, the account custodian withdraws Stonebridge Financial Group, LLC’s advisory fees directly from the clients’ accounts according to the custodian’s policies, practices, and procedures. The custodial statement includes the amount of any fees paid to SFG for advisory services. You should carefully review the statement from your custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker- dealer does not verify the accuracy of fee calculations. Fees for Asset Management and Cash Management are charged in advance on a quarterly basis, meaning that advisory fees for a quarter are charged on the first day of the quarter. Clients may terminate investment advisory services obtained from SFG, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with SFG. The client is responsible for any fees and charges incurred by the client from third parties as a result of maintaining the account such as transaction fees for any securities transactions executed and account maintenance or custodial fees. Thereafter, the client may terminate advisory services upon written notice delivered to and received by SFG. Clients who terminate investment advisory services during a quarter are charged a prorated advisory fee based on the date of SFG’s receipt of client’s written notice to terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and unearned fees will be immediately refunded. Financial Planning – Financial planning services are charged in arrears through a fixed fee or hourly arrangement as agreed upon between the client and Stonebridge Financial Group, LLC. There will never be an instance where $1,200 or more in fees is charged six or more months in advance. Hourly fees are generally charged when the scope of services cannot be determined or if the services are limited to one meeting. Fixed fees are generally quoted to the client for longer term consulting projects. Fees are negotiable and vary depending upon the complexity of the client situation and the services to be provided. Hourly fees range from $250 - $350 per hour, depending on what is negotiated between SFG and the client, with an initial planning fee minimum of $5,000. Similar financial planning services may be available elsewhere for a lower cost to the client. Fixed fees for longer-term consulting projects range from $3,000 to $5,000 per project. An estimate for total hours and charges is determined at the start of the advisory relationship. Typically, clients will be invoiced monthly for all time spent by SFG as agreed upon by client or upon completion of the services if less than a month. Clients who wish to terminate the planning process prior to completion may do so with written notice. The client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period by 6  contacting Cody Gehman at (717) 736-7007. Upon receipt of written notification, any earned fee will immediately become due and payable, and any prepaid and unearned fees will be immediately refunded. A client may terminate an advisory agreement without being assessed any fees or expenses within five (5) days of its signing. Retirement Plan Services - Retirement Plan Services, whether a 3(38) or 3(21) account, will result in a separate fee payable to SFG; for plans with assets of $800,000 or more, annual fees are a maximum of 1.00%. Plans with assets less than $800,000 will be charged a flat fee of $4,000. These fees are billed quarterly in advance or in arrears, depending on the Agreement. Cash Balance Plan Services - Cash Balance Plan Services will result in a separate fee payable to SFG. Annual fees are a maximum of 1.50%. These fees are billed quarterly in advance or in arrears, depending on the Agreement. Bonus Compensation – Certain IARs of SFG are involved in providing consulting services to company-sponsored retirement plans. These IARs receive a one-time bonus if an individual at a client company chooses to become an investment advisory client of SFG. This presents a conflict of interest, as it means these IARs have a financial incentive to recommend that you transition to our retail advisory services. Despite this incentive, we are obligated to act in your best interest when making any recommendations. Additional Fees and Expenses - In addition to advisory fees paid to SFG as explained above, clients may pay custodial service, account maintenance, transaction, and other fees associated with maintaining the account. These fees vary by broker and/or custodian. Clients should ask SFG for details on transaction fees or other custodial fees specific to their account, as these fees are not included in the annual advisory fee. SFG does not share any portion of such fees. Additionally, for any mutual funds purchased, the client may pay their proportionate share of the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are not shared with SFG and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to investing. Mutual fund companies impose internal fees and expenses on clients. These fees are in addition to the costs associated with the investment advisory services as described above. Complete details of such internal expenses are specified and disclosed in each mutual fund company’s prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such securities. Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund management fees may be more or less than the mutual fund management fees charged if the client held the mutual fund directly with the mutual fund company. Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal underwriter, or a distributor without purchasing the services of SFG or paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the applicable advisory fee. However, clients would not receive SFG’s assistance in developing an 7  investment strategy, selecting securities, monitoring performance of the account, and making changes as necessary. Please refer to Item 12 “Brokerage Practices” of this brochure for additional information. Rollovers – SFG and our advisory personnel have a financial incentive when you, as a plan participant, decide to roll over assets from an external retirement plan (such as a 401(k) or IRA with another institution) into a retirement plan that our firm manages. When you roll over assets into a plan we manage, those assets are included in the total assets upon which our firm calculates its ongoing advisory fee. This means that a rollover increases the assets we manage and, thus, increases the advisory fee revenue our firm receives. This creates a financial incentive for our firm to recommend or encourage such rollovers. This incentive exists regardless of whether remaining in your current plan, rolling over to another provider, or choosing a different option might be equally or more beneficial for you when considering all relevant factors, including fees, services, investment options, and your individual financial situation. We are fiduciaries and are required to act in your best interest. To address this conflict, we require our advisors to provide you with information about your various options concerning your retirement assets, including leaving them in your former employer's plan (if permissible), rolling them over to an IRA (at our firm or another firm), or rolling them into a new employer's plan (if permissible). Form ADV, Part 2A, Item 6 Performance-Based Fees and Side-By-Side Management Stonebridge Financial Group, LLC does not charge performance-based fees or participate in side-by-side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and Compensation section above and are not charged on the basis of performance of your advisory account. Form ADV, Part 2A, Item 7 Types of Clients SFG offers investment advisory services to individuals, high net worth individuals, charitable organizations, corporations, and pension plans. There is no minimum account size to open and maintain an advisory account. Form ADV, Part 2A, Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss SFG’s methods of analysis and investment strategies incorporate the client’s needs and 8  investment objectives, time horizon, and risk tolerance. SFG is not bound to a specific investment strategy for the management of investment portfolios, but rather consider the risk tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis. Examples of methodologies that our investment strategies may incorporate include: Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount of securities at regularly scheduled intervals, regardless of the price per share. This will gradually, over time, decrease the average share price of the security. Dollar-cost averaging lessens the risk of investing a large amount in a single investment at the wrong time. Technical Analysis – involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short term price fluctuations. Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. These risks include market risk, interest rate risk, issuer risk, and general economic risk. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks, as they all bear risks. SFG’s primary goal for investing is to help the client maintain purchasing power over the long term. This may result in short term variability and loss of principal. Time horizon and risk tolerance are key determinates of the proper asset allocation. SFG’s approach focuses on taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or lack of portfolio risk). Below are some more specific risks of investing: Market Risk. The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose 9  securities are owned by the client or an underlying fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Management Risk. SFG’s investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or underlying fund is not realized in the expected time frame, the overall performance of client’s portfolio may suffer. Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may be affected by adverse political, legislative and tax changes, as well as by financial developments that affect the municipal issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds generally are traded in the “over-the-counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. SFG has no control over the risks taken by the 10  underlying funds. Form ADV, Part 2A, Item 9 Disciplinary Information Stonebridge Financial Group, LLC or its Principal Executive Officers have not had any reportable disclosable events in the past ten years. Form ADV, Part 2A, Item 10 Other Financial Industry Activities and Affiliations Some representatives of SFG are separately licensed as registered representatives of an unaffiliated broker-dealer. These individuals, in their separate capacity, can effect securities transactions for which they will receive separate, yet customary compensation. Some representatives of SFG are also licensed insurance agents. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. SFG always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SFG in their capacity as an insurance agent. Not more than 30% of these representatives’ time is spent on this activity. Some representatives may also be registered with investment advisors other than our firm. The fiduciary standard to the client will be always met regardless of which entity they are representing when acting on the client’s behalf. Clients are in no way required to utilize the services of other investment advisors when engaged with SFG. SFG is affiliated with several other non-investment advisory businesses. These other non-investment advisory businesses offer non-advisory services such as payroll and human resource solutions and insurance products, including Medicare plans. IARs may recommend these affiliated services. This creates a conflict of interest because our affiliates earn additional compensation if clients use these services, potentially incentivizing recommendations that may not be the most suitable or cost-effective for clients compared to unaffiliated options. Clients are never obligated to use any recommended affiliated service Certain principals of SFG also own a portion of MPC Insurance Group (“MPC”), an insurance and advisory service company that provides health and financial security solutions such as Medicare plans. This creates a potential conflict of interest as these owners may have a financial incentive to encourage clients of the SFG to utilize the services of MPC. SFG representatives, in their discussions with plan participants and clients, may refer individuals to MPC for Medicare insurance services. This referral practice presents a potential conflict of interest. Plan participants and clients are under no obligation to utilize the services of MPC and are free to explore other Medicare insurance providers. Neither SFG nor its representatives are registered as a Futures Commission Merchant, Commodity 11  Pool Operator, or a Commodity Trading Advisor. Form ADV, Part 2A, Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading SFG’s Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect client interests at all times and to demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of SFG’s Associated Persons are expected to strictly adhere to these guidelines. Persons associated with Stonebridge Financial Group, LLC are also required to report any violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about our clients or client accounts by persons associated with our firm. SFG and its employees may buy or sell securities that are also held by clients. It is the expressed policy of the advisor that no person employed by our firm purchase or sell any security prior to the transaction being implemented for an advisory account; therefore, preventing such employees from benefiting from transactions placed on behalf of the advisory clients. The advisor may have an interest or position in a certain security, which may also be recommended to the client. As these situations may present a conflict of interest, the advisor has established the following restrictions in order to ensure its fiduciary responsibilities should this issue ever arise: 1. A director, officer or employee of the advisor shall not buy or sell a security for their personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of his or her employment, unless the information is also available to the investing public. No owner/employee of SFG shall prefer their own interest to that of the client. 2. The advisor maintains a list of all securities held by the company and all directors, officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the firm. 3. The advisor requires that all employees must act in accordance with all applicable Federal and State regulations governing registered investment advisors. 4. The advisor may block personal trades with those of clients but will ensure that clients are not at a disadvantage. SFG’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting Cody Gehman at (717) 736-7007. Form ADV, Part 2A, Item 12 Brokerage Practices In order for SFG to provide asset management services, we request you utilize the brokerage and custodial services of Charles Schwab & Co., Inc. (“Schwab”), for which we have an existing relationship. SFG and Schwab are not affiliated companies. In considering which independent qualified custodian will be the best fit for SFG’s business model, we are evaluating the following 12  factors, which is not an all-inclusive list:  Financial strength  Reputation  Reporting capabilities  Execution capabilities  Pricing, and  Types and quality of research While you are free to choose any broker-dealer or other service provider, we recommend that you establish an account with a brokerage firm with which we have an existing relationship. Such relationships may include benefits provided to our firm, including, but not limited to research, market information, and administrative services that help our firm manage your account(s). We believe that recommended broker-dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by the recommended broker-dealers, including the value of research provided, the firm’s reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. You may direct us in writing to use a particular broker-dealer to execute some or all of the transactions for your account. If you do so, you are responsible for negotiating the terms and arrangements for the account with that broker-dealer. We may not be able to negotiate commissions, obtain volume discounts, or best execution. In addition, under these circumstances a difference in commission charges may exist between the commissions charged to clients who direct us to use a particular broker or dealer and other clients who do not direct us to use a particular broker or dealer. SFG does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. SFG does not have any formal soft dollar arrangements. When SFG buys or sells the same security for two or more clients (including our personal accounts), we may place concurrent orders to be executed together as a single “block” in order to facilitate orderly and efficient execution. Each client account will be charged or credited with the average price per unit. We receive no additional compensation or remuneration of any kind because we aggregate client transactions. No client is favored over any other client. If an order is not completely filled, it is allocated pro-rata based on an allocation statement prepared by SFG prior to placing the order. Because of an order’s aggregation, some clients may pay higher transaction costs, or greater spreads, or receive less favorable net prices on transactions than would otherwise be the case if the order had not been aggregated. YOUR BROKERAGE AND TRADING COSTS For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds, and U.S. exchange-listed equities and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For some types of accounts and upon our request, Schwab will charge you a percentage of the dollar amount of assets in the account in lieu 13  of commissions, where we have determined that this pricing structure is appropriate for your account . In cases where we choose to execute a trade with different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, to minimize your trading costs, we have Schwab execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trade through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). By using another broker or dealer you may pay lower transaction costs. PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis and at no charge to us as long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab. Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, record keeping, and client reporting 14  Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. OUR INTEREST IN SCHWAB’S SERVICES The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/custodians”) and not Schwab’s services that benefit only us. Form ADV, Part 2A, Item 13 Review of Accounts Client accounts are reviewed at least quarterly by Cody Gehman, Chief Compliance Officer of the firm. Cody Gehman reviews clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at SFG are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Cody Gehman, Principal Executive Officer of the firm. There is only one level of review and that is the total review conducted to create the financial plan. 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). Each client will receive at least quarterly a written report that details the clients’ account which may come from the custodian. Clients are encouraged to review these statements to verify accuracy and calculation correctness. 15  Form ADV, Part 2A, Item 14 Client Referrals and Other Compensation Our firm may engage in promoter arrangements for client referrals. These individual promoters offer our services to the public. The Firm pays a referral fee to the promoter based on a portion of the management fees charged by the Firm and memorialized in a written agreement (“Promoter Agreement”). In all cases, the Firm will comply with the cash solicitation rules established by the SEC, state regulators and the client disclosure requirements. If a referred prospective client enters into an investment advisory agreement with the Firm, a referral fee is paid to the referring party. The referral relationship will not result in clients being charged any fees over and above the normal advisory fees charged for the advisory services provided. The Firm will pay the promoter their share of the total fee. The Promoter Agreement requires that the promoter be appropriately registered under federal and state securities laws where applicable. Clients receive all related agreements and disclosures prior to or at the time of entering into an Investment Advisory Agreement with the Firm. SFG has entered into solicitor agreements with Collaborative Advisory Group and Stambaugh Ness Wealth Management (collectively the “Solicitors”) under which the Solicitors refer prospective clients to Stonebridge for investment advisory services. In exchange for these referrals, Stonebridge pays the Solicitors a portion of the advisory fees collected from referred clients. Specifically, the Solicitors receive 20% of the net investment advisory fees that Stonebridge earns from such clients on an ongoing basis. This arrangement creates a conflict of interest, as the Solicitors have a financial incentive to recommend Stonebridge's services. To mitigate this conflict and ensure transparency, all referred clients receive a written solicitor disclosure that outlines the nature of the arrangement, the compensation to be received by the Solicitors, and any potential conflicts of interest. Clients also receive Stonebridge's Form ADV Part 2A and Client Relationship Summary (Form CRS) prior to or at the time of entering into an advisory agreement. SFG does not receive compensation for referring clients to other professional service providers. Form ADV, Part 2A, Item 15 Custody SFG does not have physical custody of any client funds and/or securities and does not take custody of client accounts at any time. Client funds and securities will be held with a bank, broker dealer, or other independent qualified custodian. However, by granting SFG written authorization to automatically deduct fees from client accounts, SFG is deemed to have limited custody. You will receive account statements from the independent, qualified custodian holding your funds at least quarterly. The account statement from your custodian will indicate the amount of advisory fees deducted from your account(s) each billing cycle. Clients should carefully review statements received from the custodian. Under securities regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct Schwab to deduct our advisory fees directly from your account or if you grant us authority to move your money to another person’s account. Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least 16  quarterly. They will be sent to the email or postal mailing address you provided to Schwab. You should carefully review those statements promptly when you receive them. Some clients may execute limited powers of attorney or other standing letters of authorization that permit the firm to transfer money from their account with the client’s independent qualified Custodian to third-parties. This authorization to direct the Custodian may be deemed to cause our firm to exercise limited custody over your funds or securities and for regulatory reporting purposes, we are required to keep track of the number of clients and accounts for which we may have this ability. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate any transfers that may have taken place within your account(s) each billing period. You should carefully review account statements for accuracy. Form ADV, Part 2A, Item 16 Investment Discretion Before SFG can buy or sell securities on your behalf, you must first sign our discretionary management agreement, a limited power of attorney, and/or trading authorization forms. By choosing to do so, you may grant the firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Clients may impose limitations on discretionary authority for investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary authority are required to be provided to the IAR in writing. Please refer to the “Advisory Business” section of this Brochure for more information on our discretionary management services. Form ADV, Part 2A, Item 17 Voting Client Securities We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. 17  Form ADV, Part 2A, Item 18 Financial Information SFG is not required to provide financial information to our clients because we do not require or solicit the prepayment of more than $1,200 six or more months in advance. Form ADV, Part 2A, Item 19 Requirements for State-Registered Advisers This section is not applicable as SFG is SEC registered and not state registered. 18 

Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure Form ADV, Part 2A, Item 1 Cover Page Stonebridge Financial Group, LLC 602 North Front Street Wormleysburg, Pennsylvania 17043 26A East Roseville Road Lancaster, Pennsylvania 17601 Tel: (717) 736-7007 Fax: (717) 761-6127 August 2025 FORM ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE This brochure provides information about the qualifications and business practices of Stonebridge Financial Group, LLC. If you have any questions about the contents of this brochure, please contact us at (717) 736-7007. 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 Stonebridge Financial Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Stonebridge Financial Group, LLC is 327529. 1  Form ADV, Part 2A Appendix 1, Item 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of any material changes to this and subsequent brochures by April 30th. We will further provide you with our most recent brochure at any time at your request, without charge. You may request a brochure by contacting us at (717) 736-7007. Material Changes since the Last Update The following material changes have been made since the last update filed on May 6, 2025: • Item 5 – Fees and Compensation – Stonebridge Financial Group, LLC updated this section to identify an inherent conflict when SFG encourages rollovers and the assets under SFG’s management increases leading to an increase in revenue. SFG also updated this section to disclose that certain SFG personnel who provide company-sponsored retirement plan consulting services can receive a one-time bonus when they successfully refer individuals at client companies to become advisory wealth management clients of SFG. 2  Form ADV, Part 2A Appendix 1, Item 3 Services, Fees and Compensation 4 Fees and Compensation 6 Account Requirements and Types of Clients 9 Portfolio Manager Selection and Evaluation 9 Client Information Provided to Portfolio Managers 14 Client Contact With Portfolio Managers 14 Requirements for State-Registered Advisers 16 3  Form ADV Part 2A Appendix 1, Item 4 Services, Fees and Compensation Stonebridge Financial Group, LLC (hereinafter referred to as "SFG") is a Registered Investment Adviser based in Wormleysburg, Pennsylvania, and incorporated under the laws of the State of Pennsylvania. SFG is owned by Brian McCarver and Jonathan Freeman. SFG is registered with the Securities and Exchange Commission (“SEC”) and subject to the rules and regulations of the US Investment Advisers Act of 1940, as amended (the "Advisers Act").. In November 2023, Stonebridge Financial Group, LLC became an independently registered investment advisor, and provides investment advisory services, which may include, but are not limited to, the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification. Please note e-mail is an acceptable form of written notification for these purposes. SFG also provides financial planning consulting services including, but not limited to, risk assessment/management, investment planning, estate planning, financial organization, or financial decision making/negotiation and retirement planning. A “wrap fee program” for purposes of the SEC is a program under which investment advisory and brokerage execution services are provided for a single “wrapped” fee that is not based on the transactions in a client account. SFG provides discretionary and non-discretionary investment advisory services to some of its clients through a managed account program (“the Wrap Fee Program”). SFG will assist clients in determining the suitability of the Wrap Fee Program for the client. In order for SFG to provide asset management services, we request you utilize the brokerage and custodial services of Charles Schwab & Co., Inc. (“Schwab”), for which we have an existing relationship. Schwab and Stonebridge Financial Group, LLC are separate and unaffiliated. Products & Services Available to Us From Schwab Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis and at no charge to us as long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab. 4  Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  provides access to client account data (such as duplicate trade  confirmations and account statements) facilitates trade execution and allocate aggregated trade orders for multiple client accounts  provides pricing and other market data   facilitates payment of our fees from our clients’ accounts assists with back-office functions, recordkeeping and client reporting Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events technology, compliance, legal, and business consulting    publications and conferences on practice management and business  succession access to employee benefits providers, human capital consultants and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons. WRAP FEE PROGRAM SFG’s Wrap Fee Program is offered as a part of the Asset Management Services described above. SFG provides portfolio management services for this program based on the Client’s investment goals and objectives. Managed Accounts are available to primarily individuals, high net worth individuals, charitable organizations, and corporations. 5  Company-Sponsored Retirement Plan Consulting Services - Stonebridge Financial Group, LLC provides company-sponsored retirement plan consulting services (hereinafter called “retirement plan consulting services”). These services may include plan design, investment lineup selection and monitoring, plan administration support, education, co-fiduciary support, and benchmarking. We will meet with the client to discuss the major plan goals, identify key employees, evaluate employer contribution options, and analyze income tax considerations. SFG will assist with the development of an appropriate investment strategy that reflects the plan sponsor’s stated investment objectives for management of the plan. SFG will design an investment lineup that meets the plan sponsor’s goals and objectives and will monitor the investments for potential changes. To conduct certain retirement plan consulting services, SFG will utilize discretionary authority to install platforms, add or remove funds to the plan’s investment portfolio, amend the weightings of the fund components, move funds from the various models in use, etc. Fees and Compensation The following types of fees will be assessed: Asset Management – Fees are charged quarterly in advance and are based primarily on asset size and the level of complexity of the services provided. In individual cases, SFG has the sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on the share of capital gains or capital appreciation of the funds or any portion of the funds. Comparable services for lower fees may be available from other sources. Fees for the initial quarter will be prorated based upon the number of calendar days in the calendar quarter that the advisory agreement is in effect. Fees are based on the market value of the assets on the last business day of the previous quarter. Annual fees are a maximum of 2%. Consulting services are included in these fees for asset management services with the exception of unique circumstances that may require a separate agreement for financial planning services (description and fees are discussed below). If the situation warrants separate financial planning fees, it will be discussed upfront and a separate agreement will be negotiated. Account Maintenance Fee – Each Asset Management account will be charged a management fee on a calendar quarterly basis, which will be billed in advance of each calendar quarter. Each nondiscretionary account where the client requests to have the nondiscretionary account integrate and/or feed into Stonebridge's Black Diamond software for performance reporting purposes will be charged a quarterly account maintenance fee of $25 per quarter. Option Account Fee – An additional flat fee percentage, on top of the tiered or breakpoint fee, will be applied to the billable assets of accounts with options trading authorized. Option Account Fee range from 0.25% - 0.5%. Accounts With Margin – Certain client accounts may have margin; however, it is not Stonebridge Financial Group, LLC’s practice to trade on margin, therefore when advisory fees 6  are calculated the firm uses the market value of client accounts. The market values of client accounts are derived from our custodian. Terms – As authorized in the client agreement, the account custodian withdraws SFG’s advisory fees directly from the clients’ accounts according to the custodian’s policies, practices, and procedures. The custodian in turn remits these fees to SFG. The custodial statement includes the amount of any fees paid directly to SFG to manage the account. You should compare the statement we send to your custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker-dealer does not verify the accuracy of fees calculations. If the account does not contain sufficient funds to pay advisory fees, SFG has limited authority to sell or redeem securities in sufficient amounts to pay advisory fees. With the exception of IRA accounts, clients may reimburse the account for advisory fees paid to SFG. Fees are charged in advance on a quarterly basis, meaning that advisory fees for a quarter are charged on the first day of the quarter. Clients may terminate investment advisory services obtained from SFG, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with SFG. The client is responsible for any fees and charges incurred by the client from third parties as a result of maintaining the account such as transaction fees for any securities transactions executed and account maintenance or custodial fees. Thereafter, the client may terminate advisory services upon written notice delivered to and received by SFG. Clients who terminate investment advisory services during a quarter are charged a prorated advisory fee based on the date of SFG’s receipt of client’s written notice to terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and unearned fees will be immediately refunded. Financial Planning – Financial planning services are charged in arrears through a fixed fee arrangement as agreed upon between the client and SFG. There will never be an instance where $1,200 or more in fees is charged six or more months in advance. Hourly fees are generally charged when the scope of services cannot be determined or if the services are limited to one meeting. Hourly fees range from $250 - $350 per hour, depending on what is negotiated between SFG and the client. Similar financial planning services may be available elsewhere for a lower cost to the client. Fixed fees are generally quoted to the client for longer term consulting projects. Fees are negotiable and vary depending upon the complexity of the client situation and services to be provided. Fixed fees are $3,000 - $5,000 per plan. Similar financial planning services may be available elsewhere for a lower cost to the client. Clients may be invoiced monthly for all time spent by SFG as agreed upon by client or upon completion of the services if less than a month. Clients who wish to terminate the planning process prior to completion may do so with written notice. Upon receipt of written notification, any earned fee will immediately become due and payable, and any prepaid and unearned fees will be immediately refunded. A client may terminate an advisory agreement without being assessed any fees or expenses within five (5) days of its signing. Retirement Plan Services - Retirement Plan Services, whether a 3(38) or 3(21) account, will result in a separate fee payable to SFG; for plans with assets of $800,000 or more, annual fees are a maximum of 1.00%. Plans with assets less than $800,000 will be charged a flat fee of $4,000. These fees are billed quarterly in advance or in arrears, depending on the Agreement. 7  Cash Balance Plan Services - Cash Balance Plan Services will result in a separate fee payable to SFG. Annual fees are a maximum of 1.50%. These fees are billed quarterly in advance or in arrears, depending on the Agreement. Bonus Compensation – Certain IARs of SFG are involved in providing consulting services to company-sponsored retirement plans. These IARs receive a one-time bonus if an individual at a client company chooses to become an investment advisory client of SFG. This presents a conflict of interest, as it means these IARs have a financial incentive to recommend that you transition to our retail advisory services. Despite this incentive, we are obligated to act in your best interest when making any recommendations. Rollovers – SFG and our advisory personnel have a financial incentive when you, as a plan participant, decide to roll over assets from an external retirement plan (such as a 401(k) or IRA with another institution) into a retirement plan that our firm manages. When you roll over assets into a plan we manage, those assets are included in the total assets upon which our firm calculates its ongoing advisory fee. This means that a rollover increases the assets we manage and, thus, increases the advisory fee revenue our firm receives. This creates a financial incentive for our firm to recommend or encourage such rollovers. This incentive exists regardless of whether remaining in your current plan, rolling over to another provider, or choosing a different option might be equally or more beneficial for you when considering all relevant factors, including fees, services, investment options, and your individual financial situation. We are fiduciaries and are required to act in your best interest. To address this conflict, we require our advisors to provide you with information about your various options concerning your retirement assets, including leaving them in your former employer's plan (if permissible), rolling them over to an IRA (at our firm or another firm), or rolling them into a new employer's plan (if permissible). Additional Fees and Expenses - In addition to advisory fees paid to SFG as explained above, clients are charged custodial service, account maintenance, transaction, and other fees associated with maintaining the account, however SFG pays some or all of these fees for designated Wrap Accounts. Therefore, these fees are included in the fee stated above. These fees vary by broker dealer and/or custodian. Additionally, for any mutual funds purchased, the client may pay their proportionate share of the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are not shared with SFG and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to investing. Mutual fund companies impose internal fees and expenses on clients. These fees are in addition to the costs associated with the investment advisory services as described above. Complete details of such internal expenses are specified and disclosed in each mutual fund company’s prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such securities. Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund management fees may be more or less than the mutual fund management fees charged if the client held the mutual fund directly with the mutual fund company. 8  Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal underwriter, or a distributor without purchasing the services of SFG or paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the applicable advisory fee. However, clients would not receive SFG’s assistance in developing an investment strategy, selecting securities, monitoring performance of the account, and making changes as necessary. The fees not included in the advisory fee for our wrap services are charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), fees for trades executed away from the custodian, mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Schwab has eliminated commissions for online trades of equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. Form ADV, Part 2A Appendix 1, Item 5 Account Requirements and Types of Clients SFG offers investment advisory services primarily to individuals, high net worth individuals, charitable organizations, and corporations. There is no minimum account size to open and maintain an advisory account. Form ADV, Part 2A Appendix 1, Item 6 Portfolio Manager Selection and Evaluation SFG may act as the portfolio manager for its Wrap Fee Program accounts. There is no conflict of interest with the arrangement. Advisory Business Stonebridge Financial Group, LLC is a Registered Investment Adviser based in Wormleysburg, Pennsylvania, and incorporated under the laws of the State of Pennsylvania. SFG is owned by 9  Brian McCarver and Jonathan Freeman. SFG is registered with the SEC and subject to the rules and regulations of the US Advisers Act. In November 2023, Stonebridge Financial Group, LLC became an independently registered investment advisor, and provides investment advisory services, which may include, but are not limited to, the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an acceptable form of notification. SFG also provides financial planning consulting services including, but not limited to, risk assessment/management, investment planning, estate planning, financial organization, or financial decision making/negotiation and retirement planning. Stonebridge Financial Group, LLC provides investment advisory and other financial services through its Investment Advisory Representatives ("IAR") to accounts opened with Stonebridge Financial Group, LLC. Managed Accounts are available to Brian McCarver and Jonathan Freeman. Asset Management Stonebridge Financial Group, LLC provides discretionary and non-discretionary investment advisory services to some of its clients through various managed account programs. Stonebridge Financial Group, LLC will assist clients in determining the suitability of the Managed Account Programs for the client. The IAR is compensated through a comprehensive single fee and the account may be assessed other charges associated with conducting a brokerage business. The firm and its IAR, as appropriate, will be responsible for the following: • Performing due diligence • Recommending strategic asset and style allocations • Providing research on investment product options, as needed • Providing client risk profile questionnaire • Obtaining investment advisory contract from client with required financial, risk tolerance, suitability and investment vehicle selection information for each new account • Performing client suitability check on account documentation, reviewing the investment objectives and evaluating the investment vehicle selections • Providing Firm Brochure (this document) SFG may recommend a Wrap Fee Program for the client’s account(s). A “Wrap Fee Program” for purposes of the SEC is a program under which investment advisory and brokerage execution services are provided for a single “wrapped” fee that is not based on the transactions in a client account. SFG provides discretionary investment advisory services to some of its clients through 10  a Wrap Fee Program. SFG will assist clients in determining the suitability of the Wrap Fee Program for the client. Wrap Fee Program accounts recommended by SFG are not managed differently from non-Wrap Fee Program accounts. Because brokerage execution costs are included in the client’s overall advisory fee, the client’s fee may be greater than those that have accounts in non-Wrap Fee Program accounts, however fees will not exceed the fee schedule stated in this Wrap Fee Brochure. All clients with Wrap Fee Program accounts will be provided with this Wrap Fee Brochure. This Brochure is focused on Wrap Fee Program accounts. As of December 31, 2024, the firm has the following assets under management: Discretionary AUM of $1,689,661,086 and Non-Discretionary AUM of $141,632,193. Performance-Based Fees and Side By Side Management SFG does not charge performance-based fees or participate in side-by-side management. Side- by-side management refers to the practice of managing accounts that are charged performance- based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and Compensation section above, and are not charged on the basis of performance of your advisory account. Methods of Analysis, Investment Strategies, and Risk of Loss SFG’s methods of analysis and investment strategies incorporate the client’s needs and investment objectives, time horizon, and risk tolerance. SFG is not bound to a specific investment strategy for the management of investment portfolios, but rather consider the risk tolerance range of each portfolio and the risk level of each level when the account is opened. Examples of methodologies that our investment strategies may incorporate include: Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Asset Allocation has the potential of all the risks listed below. Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount of securities at regularly scheduled intervals, regardless of the price per share. This will gradually, over time, decrease the average share price of the security. Dollar-cost averaging lessens the risk of investing a large amount in a single investment at the wrong time. Dollar-Cost Averaging has the potential of all the risks listed below. Technical Analysis – involves studying past price charts, patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. Technical Analysis has the potential of all the risks listed below. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Long- Term Purchases have the potential of all the risks listed below. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ 11  short term price fluctuations. Short-term Purchases primarily have the potential of Market Risk, Business Risk, and Liquidity Risk as listed below. Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks, as they all bear risks. SFG’s primary goal for investing is to help the client maintain purchasing power over the long term. This may result in short term variability and loss of principal. Time horizon and risk tolerance are key determinates of the proper asset allocation. SFG’s approach focuses on taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or lack of portfolio risk). Below are some more specific risks of investing: Market Risk. The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by the client or an underlying fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Management Risk. SFG’s investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or underlying fund is not realized in the expected time frame, the overall performance of client’s portfolio may suffer. Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower 12  rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may be affected by adverse political, legislative and tax changes, as well as by financial developments that affect the municipal issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds generally are traded in the “over-the-counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. SFG has no control over the risks taken by the underlying funds. Voting Client Securities SFG does not vote proxies on behalf of Client advisory accounts. At the Client’s request, SFG may offer the Client advice regarding corporate actions and the exercise of proxy voting rights. If the Client owns shares of common stock or mutual funds, the Client is responsible for exercising the right to vote as a shareholder. In most cases, the Client will receive proxy materials directly from the account custodian. However, in the event SFG receives any written or electronic proxy materials, we would forward them directly to the Client by mail, unless the Client has authorized our firm to contact you by electronic mail, in which case, SFG would forward any electronic solicitation to vote proxies. 13  Form ADV, Part 2A Appendix 1, Item 7 Client Information Provided to Portfolio Managers SFG may directly provide the portfolio management services for the Wrap Fee Program accounts. As such, SFG receives all information provided by the Client through a formal Needs Analysis and consultation with the Client. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Form ADV, Part 2A Appendix 1, Item 8 Client Contact With Portfolio Managers There are no restrictions placed on SFG’s clients’ ability to contact and consult with their portfolio manager(s). Form ADV, Part 2A Appendix 1, Item 9 Additional Information Disciplinary Information SFG or its Principal Executive Officers have not had any reportable disclosable events in the past ten years. Other Financial Industry Activities and Affiliations Some representatives of SFG are separately licensed as registered representatives of an unaffiliated broker-dealer. These individuals, in their separate capacity, can effect securities transactions for which they will receive separate, yet customary compensation. Some representatives of SFG are also licensed insurance agents. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. SFG always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of SFG in their capacity as an insurance agent. Not more than 30% of these representatives’ time is spent on this activity. Some representatives may also be registered with investment advisors other than our firm. The fiduciary standard to the client will be always met regardless of which entity they are representing when acting on the client’s behalf. Clients are in no way required to utilize the services of other investment advisors when engaged with SFG. 14  Certain principals of SFG also own a portion of MPC Insurance Group (“MPC”), an insurance and advisory service company that provides health and financial security solutions such as Medicare plans. This creates a potential conflict of interest as these owners may have a financial incentive to encourage clients of the SFG to utilize the services of MPC. SFG representatives, in their discussions with plan participants and clients, may refer individuals to MPC for Medicare insurance services. This referral practice presents a potential conflict of interest. Plan participants and clients are under no obligation to utilize the services of MPC and are free to explore other Medicare insurance providers. Neither SFG nor its representatives are registered as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading SFG’s Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect client interests at all times and to demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of SFG’s Associated Persons are expected to strictly adhere to these guidelines. Persons associated with SFG are also required to report any violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about our clients or client accounts by persons associated with our firm. SFG may buy or sell securities for itself that we also recommend to clients. In addition, the individual IARs may buy or sell the same securities for their personal and family accounts that are bought and sold for your account(s). SFG does not have, nor plans to have, an interest or position in a security which is then also recommended to the client. As these situations may present a conflict of interest, the advisor has established the following restrictions in order to ensure its fiduciary responsibilities should this issue ever arise: A director, officer or employee of the advisor shall not buy or sell a security for their The advisor requires that all employees must act in accordance with all applicable The advisor will monitor any blocking of personal trades with those of clients to ensure 1. personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of his or her employment, unless the information is also available to the investing public. No owner/employee of SFG shall prefer their own interest to that of the client. 2. The advisor maintains a list of all securities held by the company and all directors, officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the firm. 3. Federal and State regulations governing registered investment advisors. 4. that clients are not at a disadvantage. SFG’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting Cody Gehman at (717) 736-7007. SFG does not recommend or select other investment advisors to our clients for which we receive compensation, directly or indirectly, from those advisors, nor do we have business relationships with any other investment advisors. 15  Review of Accounts Client accounts are reviewed at least quarterly by Cody Gehman, the Chief Compliance Officer of the firm. Client accounts are reviewed with regard to their investment policies and risk tolerance levels. All accounts at SFG are reviewed by this reviewer. Reviews may also 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). Each client will receive at least quarterly a written report that details the clients’ account which may come from the custodian. Clients are encouraged to review these statements to verify accuracy and calculation correctness. Client Referrals and Other Compensation Our firm may engage in promoter arrangements for client referrals. These individual promoters offer our services to the public. The Firm pays a referral fee to the promoter based on a portion of the management fees charged by the Firm and memorialized in a written agreement (“Promoter Agreement”). In all cases, the Firm will comply with the cash solicitation rules established by the SEC, state regulators and the client disclosure requirements. If a referred prospective client enters into an investment advisory agreement with the Firm, a referral fee is paid to the referring party. The referral relationship will not result in clients being charged any fees over and above the normal advisory fees charged for the advisory services provided. The Firm will pay the promoter their share of the total fee. The Promoter Agreement requires that the promoter be appropriately registered under federal and state securities laws where applicable. Clients receive all related agreements and disclosures prior to or at the time of entering into an Investment Advisory Agreement with the Firm. SFG does not receive compensation for referring clients to other professional service providers. Financial Information SFG is not required to provide financial information to our clients because we do not require or solicit the prepayment of more than $1,200 six or more months in advance. Form ADV, Part 2A Appendix 1, Item 10 Requirements for State-Registered Advisers This section is not applicable as SFG is SEC registered and not state registered. 16