9AT: CIRCLE N ADVISORS, LLC

CIRCLE N ADVISORS, LLC

CIRCLE N ADVISORS, LLC

Adviser Profile

As of Date	03/16/2026
Registration	SEC, Approved, 06/26/2015
ADV Location	FISHKILL, NY, United States
Contact Info	845 xxxxxxx

AUM^*	94,202,372 -12%
of that, discretionary	94,202,372 -12%
Number of Employees	3
of those in investment advisory functions	2
Private Fund GAV^*	0
Avg Account Size	888,702 -2%
% High Net Worth	20.56% -14%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Pension and profit sharing plans

Advisory Activities

- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management

Reported AUM

116M 99M 83M 66M 50M 33M 17M

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Brochure Summary

Overview

Circle N Advisors, LLC (“Circle N”) is a Delaware Limited Liability Company formed in March 2015. Charles Frumberg is an indirect holder of 25% or more of Circle N. Circle N offers to its clients the Long-Weighted Investment Strategy, in which Circle N employees provide investment advisory services to client accounts on a discretionary basis (the “Long Weighted Strategy”). Circle N offers to its clients the Long-Weighted Investment Strategy (“Long Weighted Strategy”), which utilizes a long portfolio approach, without any options-based hedge or short positions. Circle N may structure Strategy accounts based upon individual clients’ circumstances and objectives, so the composition of each portfolio may be different, although the character of the equity portion of each account is similar. Each client can impose reasonable restrictions on the management of its account, including restricting particular securities or types of securities. If Circle N believes that the instructions are unreasonable or inappropriate for the client, Circle N may ask the client to modify the instruction, or it may terminate the account. Circle N manages the Strategy account individually and such management may involve different timing with respect to the purchase and/or sale of

particular securities, although Strategy accounts have similar foundational elements. Therefore, execution of purchases and sales of securities happen in different Strategy accounts at different times or in some Strategy accounts but not others. The liquidity of securities in the Strategy accounts, the availability of securities for purchase and different client needs and objectives affect the execution timing. Generally, all discretionary transactions in a particular security on any given day receive the same price. In the event that certain accounts are required to meet time constraints on money required for their account or for margin calls due, the related sales of securities may be exempt from the daily average price policy. In addition, Circle N may make exceptions to the daily average price policy in appropriate circumstances. Circle N may give advice and take action in the performance of its duties to a client that may differ from advice given to another client. The timing and nature of action taken with respect to Strategy accounts may differ among individual clients. Managed Assets As of December 31, 2023, Circle N Advisors LLC managed approximately $107,000,000 in assets for 118 accounts. Circle N manages all the assets on a discretionary basis.