Cambridge is a fee-based investment adviser registered with the state of New York with its business located at 6225 Sheridan Drive, Suite 102, Williamsville, NY 14221. Our firm has been in business since 2011. Scott M. McCarthy, CPA, CFP®, Member and President, is a direct owner and managing member of Cambridge. As of December 2023, Cambridge has $35,128,481 in discretionary assets under management and $7,422,518 in non-discretionary assets under management. Portfolio Management Services Cambridge provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data- gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, income tax situation, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. We will manage advisory accounts on a discretionary or non-discretionary basis, as agreed with each client. Account supervision is guided by the stated objectives of the client which are reflected in their individual Investment Policy Statement (i.e., Aggressive Growth, Capital Growth, Balanced Growth, Conservative Growth, Capital Preservation or various alternative investment options that may be desired, etc.), as well as tax considerations. Clients may impose restrictions on investing in certain securities or types of securities. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will primarily include advice regarding no-load or load- waived mutual funds, exchange-traded funds (ETFs), exchange-listed and over-the-counter securities, corporate debt securities, United States governmental securities, certificates of deposit, warrants, commercial paper, municipal securities, and private placements. Cambridge does not participate in wrap fee programs. Model Portfolio Management Services Cambridge may also manage portfolios for suitable clients through Orion Portfolio Solutions. Orion offers advisory services to Cambridge (but not directly to clients) that consist of access to asset allocation programs and investment reporting services for use in the management of client accounts. Through Orion, Cambridge may select asset allocation portfolios which diversify client assets among mutual funds/ETF’s. The mutual funds provided consist of no-load fund families and load- waived class A share funds covering all major asset classes. Each model portfolio employed represents a different asset allocation strategy. Orion retains third- party non-affiliated investment managers to design and manage model portfolios using mutual funds/ETF’s. In determining the initial allocation to be used, the client will complete a risk tolerance questionnaire which will be used to assist the client and Cambridge in determining the suitability of Orion for the client. Once the client has agreed to an initial asset allocation model, the portfolio will be implemented using the mutual funds/ETF’s available through Orion. We may suggest a reallocation of the client’s portfolio based on changing economic conditions or changes in the client’s individual circumstances. Under the Orion platform, the client will be assumed to have directed that the account be automatically invested in accordance with all adjustments and rebalancing of the asset allocation model unless the client instructs us to terminate such automatic adjustment and rebalancing. Envestnet Account Management, Inc. (Envestnet). Cambridge may recommend the use of Envestnet (Envestnet) Program separate managed account services in order to access certain investment styles or strategies deemed appropriate in light of a client’s professed financial objectives. Cambridge may access a variety of separate money managers through Charles Schwab & Co., Inc. Advisor (Charles Schwab)Envestnet Program. Through this program, Cambridge Advisors may select one or more specific asset managers to deploy model asset allocations on behalf of its clients through Envestnet Asset Management, Inc., also known as the Overlay Portfolio Manager. The Overlay Portfolio Manager will then coordinate and implement such recommendations in clients’ accounts in the form of model portfolios of all types of securities including specific Exchange Traded Funds (ETF’s) and mutual funds. Charles Schwab also allows Cambridge the option of selecting on clients’ behalf custom allocations and other features

for their account(s) which the Overlay Manager implements based upon Client’s consultation with Cambridge. As the advisor, Cambridge will be responsible for assisting the client in selecting one or more separate investment managers accessible through the Envestnet Program to achieve an appropriate asset allocation and implementation of a desired investment strategy and including the on-going monitoring of the manager(s) performance. Charles Schwab will act as custodian of the assets being managed. A client choosing to participate in an Envestnet Program shall be required to enter into various separate service agreements; one with the advisor, Cambridge, one with the Overlay Manager on behalf of each investment manager, and one with Charles Schwab to act as custodian. Alternative Investment Advisory Services Cambridge may recommend alternative investments that cannot be custodied at Charles Schwab and therefore must be either directly titled to the client or if IRA assets are being used, such assets are placed with a specialized IRA custodian. Cambridge believes in broad asset class diversification and will evaluate investment opportunities that may add an additional level of diversification to a client’s overall investment portfolio. Sometimes, these types of investments involve private placement offerings and clients are apprised of the often-associated restrictions on liquidity that may accompany these types of investments. Financial Planning Services Cambridge provides its clients with a broad range of comprehensive financial planning and consulting services (including non-investment related matters). Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and distribution plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information and analysis will be considered as they impact, and are impacted by, the entire financial and life situation of the client. In general, financial planning may address any or all of the following areas:
• Investment Advisory Services
• Retirement Accumulation and Distribution Planning
• Estate/Wealth Transfer Planning
• Income Tax Planning and Compliance
• Risk Management/Asset Protection Planning
• Elder Care/Long-Term Care
• Education Planning We gather required information through in-depth personal interviews and/or comprehensive questionnaires. Information gathered includes a client's current financial status (i.e. Net-Worth Statement), current and anticipated cash-flows, future goals and attitudes towards risk. We carefully review related documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Implementation of financial plan recommendations is entirely at the client's discretion. If a client wishes, and to the extent possible, Cambridge is available to assist in the implementation of our financial planning recommendations. Our financial planning recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. If requested by the client, we may recommend the services of other professionals (i.e., attorneys, actuaries, etc.) for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from us. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Cambridge if there are ever any changes in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Consulting Services to 401(K) Pension and Profit-Sharing Plans Cambridge may enter into an agreement to provide guidance to the Trustee(s) or Board of Trustees of 401(k), Pension and Profit Share Plans to assist them in managing their fiduciary obligations and other activities as directed by the Trustee or Board of Trustees. In this capacity, we may attend quarterly meetings, may assist in the preparation of the Investment Policy Statement (IPS), may assist in the selection of investments, monitor client’s investments according to the adopted IPS, and participate in employee communications and education programs. The fee charged for services shall be a percentage of the plan’s assets under advisement and will be contained in a signed Consultation Agreement with each plan trustee.