Saperston Legacy Advisors, Inc. is a SEC-registered investment adviser with its principal place of business located in New York. Saperston Legacy Advisors, Inc. (formerly Willard B. Saperston, Inc.) began conducting business in 1989. Listed below are the firm's principal shareholder(s) (individuals or entities controlling 25% or more of this company).
• Hillview III, LLC Saperston Legacy Advisors, Inc. (SLAI) offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to clients 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, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts both on a discretionary and non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities (including exchange

traded funds, ETFs)
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. SLAI provides two types of services: 1. Proprietary Asset Allocation Service - Saperston Legacy Advisors, Inc. (SLAI) provides a portfolio management program with primary emphasis on mutual funds. Conversions are made between mutual funds within a mutual fund family in accordance with signals based on indicator changes. Clients of SLAI are invested in mutual funds where a management fee is assessed as an expense, and in effect, are paying two advisory fees. 2. Proprietary Asset Allocation II Service – SLAI provides a portfolio management program with primary emphasis on stocks, bonds and ETFs. New portfolios are reviewed/evaluated by using the Dorsey Wright or Stock Charts Database for charts with positive patterns, positive relative strength and positive dividends & earnings histories. In addition, the size of the position in relation to the portfolio, along with tax costs if applicable are taken into consideration. Further analysis using the IBD (Investor’s Business Daily) Market Smith Database may be used to review a position’s fundamental as well as technical attributes. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $46,479,924 of client assets on a discretionary basis and $7,387,508 on a non-discretionary basis.