Our main focus is to manage investment portfolios for individual clients, high net worth families, charitable foundations, and small business owners. We also provide financial planning and consulting services, retirement consulting, non-investment consulting and comprehensive reporting. Our investment management services consider the client’s risk tolerance, financial goals, and objectives. A. ADE, LLC (the “Registrant”) is a limited liability company formed in June 2013 in the State of Maryland. ADE, LLC is the Registrant’s legal name, which previously was ADAG, LLC. The Registrant became registered as an investment adviser in July 2013. The Registrant also conducts business under the trade name Armstrong Dixon. The Registrant is owned and managed by Gregory Armstrong, Hugh J. Breslin IV, and Katie Brown. ADE, LLC is not owned by LPL Financial LLC, member FINRA / SIPC (the “Custodian” or “LPL Financial”). B. As discussed below, the Registrant offers investment advisory services and to the extent specifically requested by a client, financial planning, and related consulting services on a separate stand-alone basis. INVESTMENT MANAGEMENT SERVICES The client can determine to engage the Registrant to provide discretionary or non- discretionary investment advisory services. In advance of providing any recommendations or advice we require all clients review, understand and sign our Investment Advisory Agreement (“IAA”). This agreement goes over the terms and conditions under which we will manage a client’s assets. The IAA will include schedules of the investment accounts you wish us to manage, the specific fees, which account to bill those fees to, how to collect those fees, any positions within the accounts that are not managed or billed on, and positions that the advisor does not have discretion on (for discretionary IAA’s only). The IAA also determines if any investment advisory services will be provided to outside accounts, the fee, and which account to bill those fees to. The Registrant provides its investment management services through certain investment programs sponsored by LPL Financial. Additional details about each of these offerings, including each program’s fee arrangements and associated conflicts of interests, are available in the respective account agreement, account application, and program brochure. The IAA will remain effective until cancelled in writing by either party. In the event of a conflict between this Brochure and the IAA, the Brochure shall prevail. Advisory accounts will be held with LPL Financial. As a firm we seek a balance between risk and reward, and use a diverse blend of securities in managing accounts. We employ a strategic asset allocation approach to investing that seeks to participate in rising markets over time. We may increase or decrease cash holdings or implement various risk management strategies based on our expectations of the market behavior. The Registrant may invest in a whole range of securities and is not limited by any specific security type subject to any limitations imposed by the LPL program you select. For example, the Registrant may invest in or recommend that you invest in exchange listed securities, mutual funds, exchange traded funds, warrants, variable annuities, fixed income securities, and private placements. To the extent required, our Investment Adviser Representatives (“IARs”) must attain firm or industry registrations or equivalent experience. For information on our IARs, please request a copy of their individual brochures, which were previously provided to you at the commencement of our relationship. The following programs offered by LPL may be considered wrap fee programs, which means that clients pay a bundled fee for investment management services, trade execution, custody, and reporting: Strategic Wealth Management (SWM), Model Wealth Portfolios, and Guided Wealth Portfolios. Depending on our agreement with a client, the transaction costs in SWM may be borne by the Registrant or the client and are transaction based. If the Registrant agrees to bear transaction costs, this creates a conflict of interest because the Registrant will have a financial incentive to trade less frequently. In addition, where Registrant bears transactions costs, because transactions charges vary by security type, there is a conflict of interest for Registrant because Registrant has an incentive to select securities for your Account that incur less or no transaction fees than other types of securities. Participation in one program may cost more or less than participating in another program or purchasing these services separately. The program fee may be higher or lower than those charged by other sponsors of comparable programs. As described in greater detail under Item 4.C, certain IARs prefer certain account relationships, but there is no requirement that a client select one type of account over another. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) We offer a variety of financial, wealth-planning and business consulting services based on specific needs. Services include:
• Business Succession Planning
• Manage Family Board and/or Advisory Board
• Successor Career Path Development Planning
• Estate Planning
• Executive Compensation Planning
• Retirement Planning
• Investment Planning
• Insurance Policy Analysis
• Business Planning In order to provide our clients with a financial plan we gather information to determine a client’s objectives, make observations and provide recommendations that are designed to assist in achieving the client’s goals and objectives. Clients are under no obligation to act on our financial planning recommendations. To the extent requested by a client, the Registrant can also provide financial planning or consulting services (on investment and non-investment related matters). Prior to engaging the Registrant to provide financial planning and consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement. Neither the Registrant nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. If requested by the client, Registrant may recommend the services of other professionals, including certain of the Registrant’s representatives as registered representatives of LPL Financial or in their capacities as licensed insurance agents. (See disclosure below at Items 10.C below). The client is under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from the Registrant

and its representatives. The Registrant does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with the Registrant, if desired, in light of any changes in their financial situation or investment objectives. RETIREMENT PLAN CONSULTING The Registrant also provides non-discretionary pension consulting services, pursuant to which it assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, the Registrant shall also provide generalized participant education designed to assist participants in learning about their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between the Registrant and the plan sponsor. MISCELLANEOUS Non-Investment Consulting/Implementation Services. To the extent requested by the client, the Registrant may provide consulting services regarding non-investment related matters, such as estate, tax, and insurance planning. Neither the Registrant, nor any of its representatives, serves as an attorney or accountant and no portion of the Registrant’s services should be construed as legal or accounting services. Neither the Registrant nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. To the extent requested by a client, the Registrant may recommend the services of other professionals for certain non- investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.), including certain of the Registrant’s representatives as discussed below. Clients are under no obligation to engage the services of any recommended professional, who are responsible for the quality and competency of the services they provide. In addition, the Registrant does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with the Registrant, if desired, in light of any changes in their financial situation or investment objectives. Non-Discretionary Service Limitations. Clients that determine to engage the Registrant on a non-discretionary investment advisory basis must be willing to accept that the Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. As a result, during periods of market volatility, the Registrant will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Private Investment Funds. The Registrant may provide investment advice regarding unaffiliated private investment funds. The Registrant’s role relative to the private investment funds is limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in any private fund will be included as part of the Registrant’s “assets under management” in calculating the Registrant’s investment advisory fee. Registrant’s clients are under absolutely no obligation to consider or make an investment in a private investment fund. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that they are qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with the investment. In the event that the Registrant references private investment funds owned by the client on any account report, the value for all private investment funds will reflect the most recent valuation provided by the fund sponsor, which could be more or less than the current market value. Variable Annuities: The Registrant also may render investment management services to clients relative to variable life or variable annuity products that they may own. The Registrant either directs or recommends the allocation of client assets among the various investment subdivisions that comprise these products. The Registrant’s recommendations or decisions are limited to the investment options available. The client’s assets are maintained at the specific insurance company that issued the product that the client owns. Independent Managers. The Registrant may invest or recommend that the client invest in one or more unaffiliated independent investment managers in accordance with the client’s investment objectives. In these situations, the Independent Manager shall have day-to-day responsibility for the discretionary management of the allocated assets. The Registrant will continue to monitor and review the Independent Manager’s performance, and the client’s asset allocation and investment objectives. Factors which the Registrant considers in recommending Independent Managers include the client’s investment objectives, and the Independent Manager’s management style, performance, reputation, financial strength, reporting, pricing, and research. Client Obligations. The Registrant will not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on the information in its possession. Clients are responsible for promptly notifying the Registrant if there is ever any change in their financial situation or investment objectives so that the Registrant can review, and if necessary, revise its previous recommendations or services. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. As of February 7, 2024, the Registrant managed $312,074,067, of which $299,768,307 was managed on a discretionary basis and $12,305,760 was managed on a non- discretionary basis.