A. Firm Information Cutter Financial Group LLC (“Cutter Financial” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of the Commonwealth of Massachusetts. Cutter Financial was founded in April 2006 and is owned and operated by Jeffrey Cutter (President) and Jill Cutter (Operations Manager). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Cutter Financial. B. Conflicts of Interest Under federal and state law, Cutter Financial Group is a fiduciary and must fully disclose all material facts relating to an advisory relationship. As a fiduciary, the firm seeks to avoid conflicts of interest or, at a minimum, make full disclosure to provide sufficiently specific facts for clients to understand and appreciate the risk associated with a conflict of interest. The disclosure goal is to allow clients to provide informed consent or to decide not to engage Cutter Financial Group for services. Clients are encouraged to consider and ask questions about the select conflicts of interest listed below. Insurance Products Some investment advisor representatives of Cutter Financial Group are also insurance agents able to sell insurance products for commission compensation. Client portfolios are initially reviewed to determine the degree of market exposure compared to their risk profile and income needs. We may recommend that a portion of a client’s total portfolio may benefit from an insurance product that has features not available with a securities portfolio. Insurance products are only recommended to clients where we believe, after careful review, that the product is in each client’s best interest; insurance products are therefore not recommended to all clients. Cutterinsure, an affiliate of Cutter Financial Group, and individual insurance agents will receive commissions on all insurance product sales. Cutterinsure, Inc. Insurance products, including annuities, are offered through Cutterinsure, Inc. (MA insurance license #2080572). Cutterinsure and Cutter Financial Group are affiliated and under common control but offer services separately. Insurance companies pay commissions to Cutterinsure and advisory clients pay advisory fees to CFG. CFG employees receive compensation based on the financial performance of Cutter Financial Group as well as Cutterinsure. Advisory fees are not charged on funds used to purchase insurance products.
• Advisory fees are not reduced due to compensation received by individual insurance agents.
• The receipt of commissions provides an incentive to purchase insurance products.
• Advisory fees are not reduced due to commission compensation received. Money Managers and Product Sponsors Investment advisor representatives will, on occasion, have an opportunity to attend a training event or participate in a due diligence visit where the Money Manager or Product Sponsor will cover the associated travel expenses such as airfare, hotel and meals. Training opportunities are often held at luxury resorts where amenities such as golf, spas and entertainment are provided. Such accommodations represent a conflict of interest that can influence the evaluation of the Money Manager or Product sponsor based on factors other than the quality of services. Additional Compensation Cutter Financial Group can receive an economic benefit for providing advisory services from sources other than the client. Economic benefits include sales awards and gifts, an occasional meal, as well as entertainment such as a concert, show or sporting event. Such compensation is not directly related to the advice or services provided to a particular client, but it does create a conflict of interest that can influence the selection of services based on the compensation received. Industry Professionals When it is in the best interests of the client, Cutter Financial Group can introduce the services of other professionals for certain non-investment purposes (i.e., attorneys and accountants). Introductions represent a conflict of interest because they create a relationship where the other professional has an implied obligation to introduce potential new clients to Cutter Financial Group. Clients are under no obligation to engage the services of any such professional. If the client engages any such professional, and a dispute arises, any recourse will be exclusively from and against the engaged professional. Conflicts of interest are mitigated by the fiduciary duty to always act in a client’s best interest and acting accordingly. Cutter Financial Group will seek independent counsel to evaluate conflicts as they arise and provide sufficient disclosure and controls which may include declining to participate or proceed with an engagement. Jennifer E. Farrington, the Chief Compliance Office, is available to discuss any concerns that exist due to a conflict of interest. Dr. Farrington can be reached at (508) 388-7175 or [email protected]. Principal Owners
• Jeffrey T. Cutter, CPA/PFS, MBA, MS Co-Owner, President, Financial Advisor Mr. Cutter graduated from the Massachusetts Maritime Academy in Buzzards Bay, Massachusetts, with a Bachelor of Science (BS) in marine engineering in 1989. After graduation, Jeff had a successful career as an officer in both the U.S. Merchant Marine and the U.S. Naval Reserves. In 1993, Jeff received a sponsorship from KPMG Peat Marwick to attend the executive program at the D’Amore-McKim School of Business at Northeastern University in Boston, Massachusetts. In 12 months, he graduated with distinction, earning both a Master of Business Administration and a Master of Science in accounting. Mr. Cutter is also a certified public accountant (CPA) and earning the Personal Financial Specialist (PFS) designation. He started Cutter Financial Group, LLC in 2006 and now has offices in Mansfield, Falmouth, and Duxbury, Massachusetts.
• Jill Cutter, R.Ph Co-Owner & Office Manager Ms. Cutter is a graduate of the University of Connecticut’s School of Pharmacy and is a licensed pharmacist. She also has a life and health insurance license in Massachusetts. Jill understands the philosophies of Cutter Financial Group, LLC and is always thinking of the needs of its clients. C. Advisory Services Offered Cutter Financial Group offers investment advisory services to individuals, high net worth individuals, trusts, estates and charitable organizations (each referred to as a “Client”). The primary services provided include:
• Income Planning Analyze and maximize a Client’s current retirement income benefits, including Social Security and company pension plans, ensuring a Client has the information needed to make an informed decision. The planning provided helps to identify potential income gaps during retirement and develop sound strategies to fill those gaps.
• Investment Planning A risk-first investment strategy based on an understanding of a Client’s retirement income needs and expected sources of income. This includes advice about a long-term asset allocation strategy among securities, including stocks and bonds, and life insurance or annuity products.
• Legacy Planning Planning to protect a Client’s financial future and develop strategies for a safe and tax -efficient transfer of assets to beneficiaries, including those with special needs or charitable causes, leaving the legacy you desire. Cutter Financial Group does not provide legal advice but can work closely with a Client’s attorney during the legacy planning process.
• Risk Management Planning to account for unexpected expenses and inevitable life events, such as the death of a spouse or the need for long term care. Cutter Financial Group works with Clients to help them determine the effect on their financial plan and maximize the probability of success.
• Advance Tax Planning Planning to review a Client’s current and expected retirement tax situation. Cutter Financial Group works with Clients to establish an efficient strategy that helps to minimize tax exposure. D. Client Account Management Prior to engaging Cutter Financial to provide investment advisory services, each Client is required to enter into an agreements that defines the terms, conditions, authority of each party.
• Advisory services are tailored to the individual needs of clients.
• Clients may impose restrictions on investing in certain securities or types of securities.
• Cutter’s investment advisory contracts provide that Cutter has discretionary authority to make investment decisions in each client’s account. This means that Cutter has authority to make investment decisions in the account without consulting with the client. However, all investment decisions are required to be consistent with the mutually agreed goals, objectives and strategies. Redwood Investment Management Once a client’s risk profile and asset allocation strategy have been determined, Cutter typically invests client assets in mutual funds managed by Redwood Investment Management, based on model portfolios for each investment strategy which are provided by Redwood. Cutter has chosen to use the Redwood funds and model portfolios based on Cutter’s assessment of their value, and has no obligation to continue to do so. Cutter exercises discretion in whether and how to implement the Redwood models on a client-by-client basis. Cutter does not receive direct compensation from, or pay compensation to, Redwood; however, Redwood pays for certain expenses, such as Cutter’s travel and entertainment expenses when Cutter conducts in-person

due diligence regarding Redwood’s operations. Redwood also pays the cost of producing client binders and provides private label marketing materials that would otherwise be a Cutter expense. Such indirect compensation creates a conflict of interest that is mitigated by the firm’s fiduciary duty to act in a client’s best interest and due diligence efforts. Another conflict of interest is that Cutter has an incentive to continue to use the services provided by Redwood due to the amount of effort and internal expense required to change from one provider to another. This conflict is also mitigated by the firm’s fiduciary duty to act in a client’s best interest. Third Party Asset Management Programs (“TAMP”) Cutter Financial Group has the ability to select other investment advisors or introduce Third-Party Asset Management Programs (“TAMP”) by referral or sub-advisory arrangement. A third-party asset management program is an investment advisor selected to manage client assets on behalf of Cutter Financial Group. The process begins with a thorough assessment of the client's financial situation, investment objectives, risk tolerance, and time horizon. Once an investment strategy is established and approved by the client, the third- party asset manager takes responsibility for implementing and managing the portfolio. This includes buying and selling securities, rebalancing the portfolio periodically to maintain the desired asset allocation, and making adjustments based on market conditions or changes in the client's objectives. Sub-advisory Agreement Cutter Financial Group can enter into a sub-advisory agreement. A sub-advisory agreement is a contractual arrangement between two registered investment advisors, where one firm (the "sub-adviser") is hired by another firm (Cutter Financial Group) to manage a portion of the assets of a specific investment fund or client account. In this arrangement, Cutter Financial Group retains overall responsibility for the management of the client account, while delegating a portion of the investment decisions and portfolio management functions to the sub- advisor. The sub-advisory agreement outlines the terms and conditions of the collaboration between the two firms, including the scope of the sub-advisor's responsibilities, the compensation structure, and any other relevant terms. The agreement will clearly define the specific duties and responsibilities of the sub-advisor. This can include investment strategy, asset allocation, security selection, risk management, and performance reporting. The compensation structure for the sub-advisor is usually outlined in the agreement. Compensation can be a fixed fee, a percentage of assets under management, or a combination of both. The agreement also addresses any additional fees or expenses that the sub-advisor is entitled to receive. The non-exclusive functions of a sub-advisor generally include determining the composition and portfolio allocation, the nature and timing of the changes therein and the manner of implementing such changes, investment monitoring, and research. Cutter Financial Group delegates to the Sub-Advisor the power and authority to effectuate its investment decisions, including the execution and delivery of all investment related documents, placing trades, and billing. A sub-advisor has a fiduciary duty to Cutter Financial Group and it’s clients. Retirement Plan Rollovers An employee generally has four (4) options for their retirement plan when they leave an employer: 1. Leave the money in his/her former employer’s plan, if permitted 2. Rollover the assets to his/her new employer’s plan if one is available and permitted 3. Rollover to an Individual Retirement Account (IRA), or 4. Cash out the account value, which has significant tax considerations Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so:
• Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments.
• Employer retirement plans generally have a more limited investment menu than IRAs.
• Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds.
• Your current plan may have lower fees than our fees. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because Investment Advisor Representatives have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically be investing only in mutual funds, you should understand the cost structure of the share classes, available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. Clients should understand the various products and services they might take advantage of at an IRA provider and the potential costs of those products and services.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may also offer financial advice.
• If you keep your assets titled in a 401k or retirement account, participants could potentially delay their required minimum distribution beyond age.
• A 401(k) may offer more liability protection than a rollover IRA; each state may vary.
• Participants may be able to take out a loan on your 401k, but not from an IRA.
• IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home.
• If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital gains tax rate.
• Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. It is important to understand the differences between these types of accounts and to decide whether a rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative, or call our main number as listed on the cover page of this brochure. When Cutter Financial Group provides investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Cutter Financial Group can also provide educational services to retirement plan participants with assets that could potentially be rolled-over to an IRA advisory account. Education is based on a particular Client’s financial circumstances and best interests. Again, Advisor has an incentive to recommend such a rollover based on the compensation received, which is mitigated by the fiduciary duty to act in a Client’s best interest and acting accordingly. E. Wrap Fee Programs The SEC defines a wrap fee program to be an investment account where clients are charged a single, bundled, or “wrap” fee for investment advice, brokerage services, administrative expenses, and other fees and expenses. While wrap fee programs may be called different names - such as asset allocation program, asset management program, investment management program, mini-account, uniform managed account, or separately managed account - the defining feature is that they offer bundled investment management and brokerage services for one fee.
• Cutter Financial Group does not sponsor or act as a portfolio manager for a wrap fee program. F. Assets Under Management As of December 31, 2023, the assets under management are: Discretionary Non-Discretionary $207,310,462 $0.00 Clients may request more current information at any time.