A. Firm Information Peconic Asset Planning, Inc. ("Peconic" or the "Advisor") is a registered investment advisor located in the State of New York. Peconic was organized as a Corporation under the laws of New York in March 2002 and became a registered investment advisor in August 2020. Peconic is owned and operated by Gilbert A. Cardillo (Principal and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Peconic. Peconic Asset Planning filed its initial application to become registered as an investment adviser with the U.S. Securities Exchange Commission in February 2022, which was accepted on March 17, 2022. B. Advisory Services Offered Peconic offers investment advisory services to individuals, high net worth individuals, trusts, and estates in the State of New York and other states (each referred to as a "Client"). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Peconic provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Peconic works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to design a portfolio strategy for the Client. Peconic will then construct an investment portfol io, consisting of exchange-traded funds ("ETFs"), low-cost, diversified mutual funds, individual stocks, and/or individual bonds to meet the needs of the Client. In certain instances, the Advisor may utilize other types of investments, as appropriate for certain Clients. The firm may retain certain legacy investments held by the Client based on portfolio fit and/or tax considerations. Peconic's investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Peconic will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Peconic evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Peconic may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Peconic may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Peconic may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Clie nt, generating cash to meet Client needs, or any risk deemed unacceptable for the Client's risk tolerance. At no time will Peconic accept or maintain custody of a Client's funds or securities, except for the limited authority as outlined in Item 15 - Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 - Brokerage Practices. Retirement Plan Rollover Recommendations When Peconic provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that Peconic is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Page 5 Code (“IRC”) as applicable, which are laws governing retirement accounts. The way Peconic makes money creates conflicts with your interest so Peconic operates under a special rule that requires Peconic to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, Peconic must act as a fiduciary

to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of Peconic ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Peconic gives advice that is in your best interest;
• Charge no more than is reasonable for the services of Peconic; and
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Peconic, please know that Peconic and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Peconic. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Peconic. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Peconic receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Peconic and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Peconic or our affiliated personnel. C. Client Account Management Prior to engaging Peconic to provide investment advisory services, each Client is required to enter into an agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy - Peconic, in connection with the Client, will develop a strategy that seeks to achieve the Client's goals and objectives.
• Asset Allocation - Peconic will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction - Peconic will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. Page 6
• Investment Management and Supervision - Peconic will provide investment management and ongoing oversight of the Client's investment portfolio. D. Wrap Fee Programs Peconic includes securities transaction fees (if applicable) together with its investment advisory fee. Including these fees into a single asset-based fee is considered a "Wrap Fee Program". The Advisor sponsors the Peconic Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. The Advisor customizes its investment management services for its Clients and does not provide different services for Clients in the Wrap Fee Program. Depending on the level of trading or the security selection required for the Client's account[s], the costs for securities transaction fees borne by the Advisor may vary. Please see Appendix 1 - Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of November 29, 2022, Peconic has $32,736,233 in discretionary assets under management and $0 in non - discretionary assets under management. Clients may request more current information at any time by contacting the Advisor.