AssetGrade seeks to provide clients with an experience that addresses a client’s financial concerns in a holistic manner. The Firm anticipates being able to provide clients an intimate experience and direct interaction with their adviser to address the client’s current income, expenses, assets and liabilities. By reviewing these silos, the Firm will provide the client with an AssetGrade and will seek strategies to improve that grade. AssetGrade offers a variety of advisory services, which include financial planning, consulting, retirement plan consulting, and investment and wealth management services. Prior to the rendering of any of the foregoing advisory services, clients are required to enter into one or more written agreements with AssetGrade setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). AssetGrade has been registered as an investment adviser since September 2013 and is owned by Patrick Cote Corp., Susan Powers, and Katherine Hennessy. As of December 31, 2023 AssetGrade, had approximately $254,809,075 in regulatory assets under management, comprised of $250,717,043 of assets under management managed on a discretionary basis and $4,092,032 of assets under management managed on a non-discretionary basis. While this brochure generally describes the business of AssetGrade, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on AssetGrade’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services AssetGrade offers clients a range of financial planning and consulting services, addressing a variety of investment and non-investment related matters. These services, which are not offered on a stand-alone basis, are offered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (as described below). These services may include the following:
• Cash Flow Forecasting, including projecting future cash flows to determine how income impacts a client’s ability to achieve financial goals;
• Asset Allocation, including recommendation on implementing an investment strategy that attempts to balance investment risk with potential growth;
• Retirement Planning, including recommendations with respect to savings and investments required to support a client’s spending needs in retirement;
• Estate Planning, including analysis of exposure to estate tax and consultation on initiating new and evaluating existing estate plans;
• Financial Reporting, including producing statements that set forth a client’s financial status;
• Investment Consulting, including advice on investment strategies, asset selection, and portfolio design; and
• Risk Management, including analysis of a client’s exposure to risks that could have an adverse impact on a client’s financial matters. These services typically include between ten to forty hours of services in the first year of a client’s engagement with the Firm, and from ten to forty hours of service per year in subsequent years of a client’s engagement with the Firm. In performing these services, AssetGrade is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising AssetGrade’s previous recommendations and/or services. AssetGrade may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if

clients engage AssetGrade to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by AssetGrade under a financial planning or consulting engagement or to engage the services of any such recommended professionals, including AssetGrade itself. Investment Management and Wealth Management Services AssetGrade manages client investment portfolios on a discretionary or non-discretionary basis. For non-discretionary accounts, it is important to note that the ultimate decision to buy or sell assets within such an account lies with the investor. Further, AssetGrade may provide clients with wealth management services which generally include a broad range of comprehensive financial planning and consulting services in addition to the aforementioned discretionary and/or non-discretionary management of investment portfolios. AssetGrade primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities and options, as well as the securities components of variable annuities and variable life insurance contracts, in accordance with the investment objectives of its individual clients. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may also engage AssetGrade to advise on certain investment products that are not maintained at their primary custodian, such as assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, AssetGrade directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the custodian designated by the product’s provider. AssetGrade tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. AssetGrade consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify AssetGrade if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if AssetGrade determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. AssetGrade does not participate in a wrap fee program. Retirement Plan Consulting Services AssetGrade provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized and may include any or all of the following services: Plan Design and Strategy; Plan Review and Evaluation; Executive Planning and Benefits; Investment Management and Review; Plan Fee and Cost Analysis; Retirement Plan Committee Consultation; Fiduciary and Compliance; and Legacy Plan Services. As disclosed in the Agreement, certain of the foregoing services are provided by AssetGrade as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of AssetGrade’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Educational Seminars/Workshops AssetGrade provides periodic educational seminars and workshops to clients.