A. Description of Advisor Firm Cambridge Cape Cod Advisors, LLC (CCCA) was formed in the state of Massachusetts in 1996 as a Limited Liability Company. CCCA (also referred to as the “Advisor”) is registered as an investment advisor with the Securities and Exchange Commission (SEC). CCCA is a fee-only financial planning firm that specializes in providing holistic financial planning and investment advisory services to retired and upper-income individuals and families. CCCA may recommend the use of other portfolio investment managers, which will be detailed in this brochure (Item 4. Selection of Other Advisors), which will charge fees separate from CCCA’s fee-only services. CCCA offers a wide range of financial services, as detailed in this brochure. Specifically, by providing services to meet not only your investment needs, but also your tax, risk management, retirement planning, and business development needs. B. Description of Advisory Services Offered Comprehensive or Tailored Financial Planning The Advisor’s comprehensive or tailored financial planning services are addressed based on the needs of the client. The topics covered include any or all of the following areas of interest/concern. The client and Advisor will work together to select the specific areas to cover. These areas may include, but are not limited to, the following services: ● Monthly Cash Flow Management: The Advisor believes that what gets measured gets managed, and that personal financial management all begins with a basic understanding of your everyday spending habits. To gain this understanding, we will review your income and expenses and determine your current monthly savings or deficits, along with advice on prioritizing how any savings should be leveraged, or how expenses could be reduced if they are exceeding your income. We may also recommend an appropriate cash reserve that should be considered for emergencies such as a loss of job or an unexpected large repair, along with a review and recommendation of bank accounts (including higher interest paying money market funds) for these reserves, and strategies to meet these goals. ● Debt/Loan Management: We will provide advice on which loans to pay off first, or possibly refinance, based on factors such as your credit score, interest rates, maturity dates, and any income tax ramifications. The Advisor believes that debt with favorable low interest rates can, at times, be advantageous and leveraged to your advantage. Together, we will review all outstanding loans, including but not limited to, credit cards, student loans, home mortgages, auto loans, and personal loans, and then create a prioritized debt management plan best suited for your situation. ● Investment Analysis: This involves a review of your current portfolio, developing an asset allocation strategy that aligns with your financial goals and risk tolerance, providing information and strategies on investing in stocks, bonds, and mutual funds; reviewing employee retirement plans and stock options; as well as assisting you in establishing your own investment account at a selected custodian and picking a portfolio investment manager. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. ● Employee Benefits Optimization: We will provide a review and analysis as to whether you, as an employee, are taking advantage of the employee benefits offered to you by your employer. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. ● Financial Goals: We will help you identify specific financial goals and develop plans to attain each of them. Goals could include, but are not limited to, saving for a down payment for a home, paying off student debt, buying a new car, funding a child’s education, or saving for an upcoming vacation. We will identify what you wish to accomplish, create a budget/plan for each goal, determine how much to fund the plan and how often, and then track your progress and adjust accordingly if anything may change the timing, need, or desire to achieve each goal. ● College Savings: Includes projecting the amount of funding that will be needed to pay for a child’s public/private college or post‐secondary education. Recommendations as to tax advantages, savings plans, and investing strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid and/or the best way to contribute to a grandchild’s education (if appropriate). ● Insurance Review: Review of existing policies to ensure proper coverage for life, health, disability, liability, home, and automobile, as well as an analysis/recommendation for any savings opportunities. We can recommend affiliated licensed insurance professionals to review life and annuity opportunities. ● Retirement Planning: The Advisor’s retirement planning services typically include projections of the likelihood that you will have enough money to comfortably retire at a desired age. For situations where projections show less than optimal results, we may make recommendations that present improved possible outcomes by adjusting certain variables (i.e., working longer, saving more, spending less, taking more risks with investments). If you are near retirement or already retired, advice may be given on appropriate investment and distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. ● Tax Planning Strategies: Advice may include ways to minimize your current and future income taxes as a part of your overall financial planning strategy. For example, we may make recommendations on which type of account(s) or specific investments to be owned based in part on their “tax efficiency” or “tax-deferred status,” with consideration that there is always a possibility of future changes to federal, state and local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. From time to time, we will participate in meetings or phone calls between you and your tax professional with your approval or request. In addition, Advisors may refer clients to our affiliate, Tax Master Network, LLC, to provide tax planning input. ● Estate Planning: This typically includes an analysis of your exposure to estate taxes and establishing or reviewing your current estate plan, which may include whether you have a will, designated beneficiaries on your accounts, powers of attorney, trusts, and other related documents/plans. Our advice also may include ways for you to minimize or avoid estate taxes through implementing appropriate estate planning strategies, such as the use of applicable trusts. We always

recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time to time, we will participate in meetings or phone calls between you and your attorney with the client’s approval or request. Investment Supervisory and Management Services Should the client elect to engage the Advisor for the implementation of the financial plan, the Advisor offers investment supervisory and management services based on the individual goals, objectives, time horizons, and risk tolerance of each client. Once established, an Investment Policy Statement is created for each client, which outlines the client’s current financial situation (age, income, tax levels, and risk tolerance). The Advisor evaluates the current investments of each client and then constructs an investment plan and recommended portfolio that matches each client’s specific situation. The Advisor requires discretionary authority from clients in order to select securities, and the custodian will execute transactions without permission from the client prior to each transaction. Clients may engage the Advisor to manage and/or offer investment advice on certain investments that are not maintained at their primary custodian, such as assets held in employer-sponsored retirement plans and/or assets held in qualified tuition plans (e.g., 401(k)s, 529 plans). In these situations, the Advisor directs or recommends the allocation of client assets among the various investment options available in each plan/custodian. The Advisor’s recommended portfolios and the portfolios managed by sub-advisors generally consist of exchange-listed securities, securities traded over the counter, foreign issuers, warrants, corporate debt securities, certificate of deposit, municipal securities, Exchange Traded Funds (ETFs), mutual funds, United States government securities, variable life insurance, variable annuities, options contracts on securities and commodities, and interests in partnerships investing in real estate. Investing in these types of securities can help, but all are not necessary to diversify an investment portfolio. Advisor Agreements Investment supervisory and management services are provided under the terms of a written advisor agreement executed by the Advisor and the client. Selection of Other Advisors The Advisor periodically recommends and refers clients to either an unaffiliated third-party money manager/investment advisor or, alternatively, to our affiliate, Financial Gravity Asset Management, Inc. (FGAM), a registered investment advisor through their Managed Account programs (referred to as sub-advisors). In these arrangements, the client will enter into a program and investment advisory agreement with the sub-advisor. The Advisor will assist and advise the client in establishing investment objectives for the sub-advisor and continue to provide oversight of the client account and ongoing monitoring of the activities of the sub-advisor. The sub-advisor will develop an investment strategy to meet those objectives by identifying appropriate investments and monitoring such investments. In consideration of such services, the sub-advisor will charge a program fee that includes the investment advisory fee of the sub-advisor, the administration of the program, and trading, clearance, and settlement costs. The Advisor will add the sub-advisor’s investment advisory fee to the Advisor’s fee (described below in Item 5). The sub-advisor’s fee will be deducted from the client account monthly in arrears based on the average daily balance of the assets under management in the client account for the preceding month. Clients need to be aware that Investment Advisor Representatives of Advisor referring Clients to FGAM, presents a conflict of interest. Investment Advisor Representatives have an incentive to direct clients to FGAM as an owner of shares of stock of FGAM’s parent company, Financial Gravity Companies, Inc. (FGCO). The Advisor will always act as a fiduciary and in the best interest of the client when determining which sub-advisor to recommend. Ultimately, clients can accept or reject the recommended sub-advisor. The client, prior to entering into an agreement with a sub-advisor selected by the Advisor, will be provided with that sub-advisor’s brochure. Clients are encouraged to read the brochure in its entirety. In addition, the Advisor and its client will agree in writing that the client’s account will be managed by that selected sub-advisor on a discretionary basis. Pension Consulting Services The Advisor offers consulting services to pension or other employee benefit plans (including, but not limited to, 401(k) plans). Pension consulting may include, but is not limited to: ● identifying investment objectives and restrictions ● providing guidance on various assets classes and investment options ● recommending money managers to manage plan assets in ways designed to achieve objectives ● monitoring the performance of money managers and investment options and making recommendations for changes ● recommending other service providers, such as custodians, administrators, and broker- dealers ● creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Seminars/Workshops The Advisor also offers educational seminars or workshops on topics including general information concerning investing, financial and estate planning, business and tax planning, and the services provided by the Advisor. C. Clients Tailored Services and Client-Imposed Restrictions The Advisor will tailor its advisory services to its client’s individual needs based on meetings and conversations with the client. If clients wish to impose certain restrictions on investing in certain securities or types of securities, the Advisor will address those restrictions to have a clear understanding of the client’s requirements. For clients who are referred to sub-advisors for management of their portfolios, those sub-advisors may have established model portfolios with specific asset allocations and targets that cannot be altered by client-imposed restrictions. Clients need to be aware that the model portfolio will not be tailored to the client specifically. Some sub-advisors may be able to accommodate restrictions on investing in certain securities or types of securities, so clients will need to raise those requests with the sub-advisor. The Advisor invites clients to discuss any concerns they may have with any of the holdings in the model portfolios. D. Wrap Fee Programs Client accounts are not subject to a wrap fee program. E. Assets Under Management As of December, 2023, CCCA had $57,220,372 in discretionary and $99,066,236 in non-discretionary assets under management.