Fortress Private Ledger, LLC (hereinafter “FPL,” “the firm,” “us,” “we,” or “our”) is a registered investment adviser with its principal place of business located in Raleigh, North Carolina. We market our various advisory services using the following trade names: Archer; Fortress Advisor Network; Fortress Financial Partners; Fortress Investment Management; Fortress Private Ledger; Fortress Physicians; Fortress Retirement Plan Advisors; and Javelin 19 Opportunity Zone Advisors. Organized in 2017, FPL began conducting business as a registered investment adviser in 2018. The Joseph N. Grabar, III Revocable Trust dated May 14, 2004 is a majority owner of FPL. The Trust is entirely owned by Joseph N. Grabar who is principal and Chief Compliance Officer of FPL. As stated above, Christopher Gure owns 30% of FPL as of March 2024. FPL’s advisory services are made available to clients primarily through individuals associated with FPL as investment adviser representatives (“IARs”). For more information about the IAR providing advisory services, client should refer to the Brochure Supplement for his or her IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time client engages the IAR. Types of Advisory Services FPL offers various types of advisory services and programs including financial planning, hourly consulting, qualified opportunity zones consulting, portfolio management and ERISA-Qualified Retirement Plan consulting. This brochure provides a summary description of the above services. As further discussed in this Brochure, certain programs are offered either on a non-discretionary or discretionary basis. “Non-discretionary” services require clients to initiate or pre-approve investment transactions in their accounts before they can occur, whereas “discretionary” services authorize the IAR or other designated third-party investment adviser to buy, sell or hold investment positions without obtaining pre-approval from clients for each transaction. In addition to the programs described in this Brochure, FPL also offers Portfolio Management Services in a wrap fee program, which is disclosed in a separate Wrap Fee Brochure. In a wrap fee program, clients are charged an all-inclusive wrap fee on program assets that covers advisory, execution, third-party management, custodial and reporting services on eligible assets. A portion of these fees will be paid to FPL for advisory services. In these accounts, models are customized and managed by Fortress and available to clients for implementation in accordance with their specific risk tolerance and investment objectives. Trading and allocation of the models are performed by Fortress’ Home Office with the IAR serving as advisor responsible for monitoring and servicing the client. In a traditional account with a non-wrap fee program, research and management are separate from the cost of trading, which is paid by the client. In these accounts, the Investment Advisor serves as portfolio manager providing customized portfolios at the account level. These accounts allow for more specific mandates on trading and investment selection. For example, some clients prefer environmentally friendly companies, while others want to eliminate investments in companies producing tobacco or alcohol. The traditional account offers the client benefits by having more involvement in security selection/avoidance while their Advisor does all trading, allocation, research for their account. As such, FPL’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. The following is a summary description of advisory services covered by this Brochure. Please consult the applicable client account agreement and fee schedules for additional information and details regarding these programs. Financial Planning Services As part of FPL’s financial planning services, FPL, through its IARs, provides personal financial planning tailored to the individual needs of the client. These services may include, as selected by the client on the financial planning agreement, information and recommendations regarding tax planning, investment planning, asset allocation, retirement planning, estate needs, business needs, education planning, life and disability income protection, long-term care needs and cash flow/budget planning or any additional area of planning identified in the client engagement. The services take into account information collected from the client such as financial status, investment objective and tax status, among other data. The IAR delivers to the client a written financial plan, which may be in the form of electronic PDF, online planning reports and portals, or other equivalent electronic means. The financial planning engagement terminates upon delivery of the financial plan. Hourly Consulting Services As part of FPL’s hourly consulting services, FPL, through its IARs, provides consulting on an hourly basis. These services include, as selected by the client in the consulting agreement, advice regarding insurance planning, tax planning, investment planning, asset allocation, retirement planning, estate planning, cash flow/budget planning, business planning, education planning, personal financial planning, or any other specific service agreed to in the client engagement. The services take into account information collected from the client such as financial status, investment objective and tax status, and other data. The IAR tailors the hourly consulting services to the individual needs of the client based on the financial and investment objectives chosen by the client. The engagement terminates upon final consultation with the client which may include a written list of actionable items or recommendations in relation to the planning priorities expressed by the client. Qualified Opportunity Zones Consulting Services FPL, through IARs, provides non-discretionary investment consulting services relating to the sourcing, evaluation, underwriting, structuring, due diligence, closing, and asset management of investment opportunities in “Qualified Opportunity Funds” (as defined in Section 1400Z-2(d)(1) of the Internal Revenue Code of 1986, as amended (the “Code”) and related Treasury Regulations) planning to invest in Qualified Opportunity Zones (“QOZs”), as designated under Code Section 1400Z-1 (the “QOZ Services”). Portfolio Management Services FPL constructs and provides ongoing management of investment portfolios based on the individual needs of the client, blending together various proprietary models and/or other investments to arrive at the desired risk/reward profile and target return. Through personal discussions, in which goals and objectives based on the client’s particular circumstances are established, we develop the client’s personal investment profile. We create and manage a portfolio based on that profile. During our data-gathering process, we determine the

client’s individual objectives, time horizons, risk tolerance and liquidity needs. As appropriate, we may also review and discuss a client’s prior investment history, as well as family composition and background. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client’s behalf. Clients will retain individual ownership of all securities. In carrying out the investment mandate of the client, FPL will manage advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, growth and income, tactical allocation, etc.). We will create a portfolio consisting of one or all of the following types of securities:
• Exchange-listed securities, including exchange-traded funds (ETFs);
• Individual securities traded over-the-counter;
• Foreign issuers;
• Corporate debt securities;
• Certificates of deposit;
• Municipal securities;
• No-load or load-waived mutual funds;
• United States governmental securities; and
• Listed option contracts FPL will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. Valuing transparency and efficiency, portfolio implementation typically involves individual securities and/or ETFs. In the case of mutual funds, the selection criteria for inclusion in the portfolio may include any or all the following: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s management style and philosophy; and the fund’s management fee structure and expense ratio. FPL and its IARs will continually monitor client accounts and will re-allocate as needed in accordance with the investment objective of each account. The client should notify their IAR immediately of any material change in the client’s personal and/or financial situation which would require review or revision of the client’s account objective or allocation. If an IAR believes that a particular investment is performing inadequately, or if the IAR believes that a different investment is more suitable, then FPL will act in its fiduciary capacity to effect the change for all discretionary accounts. FPL will contact all non-discretionary clients before making any such change which may impact the timing and trade-execution of that change in the event the client is unavailable. We will meet with the client on a regular basis, no less than annually, in order to review the account holdings, performance, and allocation as well as update the client’s financial information as necessary. However, it is the responsibility of the client to notify FPL immediately of any material change in the client’s personal profile or financial situation. Examples of such items may include but not be limited to any change in address, employment status, income, investment objective, risk tolerance, or time horizon for reaching financial goals. Third-Party Investment Managers Fortress offers access to third-party investment managers who offer a wide range of asset classes and strategies through which our clients can invest. Our investment adviser representatives will typically recommend and assist the client in selecting these third-party investment managers and will consult with the client regarding those services. The third-party investment managers recommended by Fortress will manage accounts using investment discretion, meaning that the client is not required to approve every proposed transaction. Fortress may assist clients by recommending that assets be allocated among multiple managers. Whenever a client selects the services of a third-party investment manager, the client will receive a disclosure brochure similar to this one describing the manager and the services it provides. The client may also receive a disclosure brochure or a brochure supplement describing each individual portfolio manager selected. Clients should read these disclosure brochures carefully before deciding whether to select a particular portfolio manager. The list of third-party managers recommended by Fortress changes from time to time, at Fortress’s discretion. ERISA-Qualified Retirement Plan Consulting FPL provides consulting services to Employer-sponsors of ERISA qualified retirement plans to include but not be limited to 401ks, 403bs, 457 plans, Defined Benefit Plans, profit-sharing plans, and money purchase plans. Acting in a discretionary 3(38) Fiduciary capacity or a non- discretionary 3(21) Fiduciary capacity, FPL provides initial and ongoing service across the following areas of retirement plans:
• Investment Policy Statement;
• Ongoing Investment Recommendations (Manager Search and Selection);
• Investment Fund Monitoring;
• Qualified Default Investment Alternative Assistance (QDIA);
• Model Portfolios for participants; and
• Plan Performance Reporting. In addition to the services listed above, we also provide additional consulting services to include but not be limited to:
• Service Provider Liaison;
• Education Services to Plan Committee;
• Participant Enrollment;
• Participant Education;
• Plan Search Support/Vendor Analysis;
• Benchmarking Services; and
• Assistance identifying Plan fees. Based on the terms of the client service agreement for Retirement Plan Consulting, and in accordance with any Investment Policy Statement adopted by the Plan Sponsor Client, we will meet at least annually to review plan performance in aggregate as well as analyze each investment option offered to participants. Recommendations and appropriate action will be taken as to the selection, monitoring, and replacement of the investments offered in the plan. Within Portfolio Management Services, ERISA-Qualified Retirement Plan Consulting, each client can impose reasonable restrictions on the management of his/her account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should be sold if held in the account. If a client’s instructions are unreasonable or an Investment Advisor Representative believes that the instructions are inappropriate for the client, FPL will notify the client that, unless the instructions are modified, it will cancel the instructions in the client’s account. A client will not be able to provide instructions that prohibit or restrict the Investment Adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund. Assets Under Management As of December 31, 2023, FPL had $200,660,638 client assets under management; $197,829,194 is managed on a discretionary basis and $2,831,444 is managed on a non-discretionary basis.