Broadstreet Global Advisors, Inc. (hereinafter “Broadstreet” or the “firm”) is a registered investment adviser based in Somers, New York. We are a limited liability company, organized under the laws of the State of New York. We have been providing investment advisory services since 2023. Nicholas Mancini is the principal owner of Broadstreet. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, an employee, and all individuals providing investment advice on behalf of our firm. Where required, such persons are properly registered as investment adviser representatives. Currently, we offer the following investment advisory services, personalized for each individual Client:
• Wealth Management Services
• Financial Consulting Services Wealth Management Services Broadstreet offers wealth management services to Clients where we manage our client’s investments within the larger context of the client’s overall wealth management and planning process. Wealth management services consist of ongoing advice and discretionary portfolio management services. At the start of the service, an Associated Person will have one or more consultations with the Client to determine the Client’s investment objectives, risk tolerance, and other relevant information (the “suitability information”). We will also use the information we gather from our consultation(s) to create an investment strategy. As part of our overall wealth management services, we offer financial planning services typically focused on the specific needs and concerns of the client. These services cover topics such as estate and gift planning, education planning, retirement planning, risk management (insurance issues), and non-investment related matters. A financial plan may include, but is not limited to a net worth statement, cash flow statement, review of investment accounts including reviewing past asset allocations, providing asset repositioning recommendations, strategic tax planning, education planning with funding recommendations, review of retirement accounts and plans including recommendations and one or more retirement scenarios, review of insurance policies and recommendations for changes, if necessary and an estate planning review with related recommendations. Broadstreet encourages clients to work with the firm to obtain these planning services because the firm believes this planning component is beneficial in achieving the Client’s long-term financial goals. Broadstreet implements investment recommendations as part of its ongoing portfolio management service by developing a strategy that enables us to give the Client continuous and focused investment advice. As part of our portfolio management services, we customize an investment portfolio in line with the Client’s risk tolerance and investing objectives. Once we construct an investment portfolio, we will monitor your portfolio’s performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and/or the Client’s financial circumstances. Our portfolio management services are primarily offered on a discretionary basis. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you for prior approval of each transaction. These decisions are made based upon your stated investment objectives. Discretionary authority will also provide our firm with authorization to delegate discretionary investment management services to other unaffiliated Sub-Advisors selected by our firm based on your investment objectives and portfolio strategy. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. In limited circumstances and in our sole discretion, we may offer portfolio management services on a non-discretionary basis. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. Broadstreet does not recommend one particular type of security over other types of securities. We provide advice on various types of securities, including advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you ask advice. In some cases, BGA will recommend that clients invest in tax efficient private investment funds (the “TEFs”) organized as limited liability companies. The TEFs will purchase privately placed deferred variable annuity contracts (each, a “Contract”) purchased from one or more U.S. insurance companies. The investment returns on the Contracts will be linked to the performance of privately placed insurance dedicated investment funds or separately managed accounts (each, a “TEF Managed Account”) each managed by an investment manager. Broadstreet Global Advisors, Inc. may act as investment manager for some of the TEF Managed Accounts. In some cases, BGA will also recommend that clients invest in managed accounts, private equity funds, hedge funds, non-traded REITs, business development companies, limited partnerships, and other pooled investment vehicles (all of the foregoing, collectively, “Private Funds”). All Investment Managers, including Investment Managers to Private Funds recommended by our firm must either be registered as investment advisers or exempt from

registration requirements. These Investment Managers may specialize in traditional investment management or alternative strategies like private equity investments, private credit markets, hedge fund strategies, or others. Factors that we take into consideration when making our recommendations and/or selecting Private Funds include, but are not limited to, the following: the Investment Managers’ performance and methods of analysis and your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the Investment Managers’ performance to ensure that its management and investment style remain aligned with your investment goals and objectives. Interests in the TEFs and other Private Funds are offered and sold exclusively to investors satisfying the applicable eligibility and suitability requirements in private transactions. Additionally, investors are urged to carefully review the applicable offering documents for a description of the fees, investment objectives, risks and other important information associated with investing in TEFs and other Private Funds. Broadstreet will monitor your portfolio’s performance on a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions, your financial circumstances, or both. The advice we propose is designed to achieve the client’s desired goals which may require revision to meet changing circumstances. Our recommendations are based on your situation from the information provided to the firm. Management of Held Away Assets As part of our wealth management services, we provide asset allocation review, rebalancing and management services for accounts that are not held in custody of the qualified custodian(s) recommended by our firm. These services are provided through an account aggregation service called Pontera. The service primarily applies to ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and other assets that must be held in custody of the plan custodian(s). We regularly review the available investment options in these accounts, monitor them, and periodically rebalance and implement our strategies using different tools, as necessary. If you elect to allow our firm to manage your assets through Pontera, you will be notified via email when we place trades through Pontera. Under no circumstances will we possess privileges that would impute custody to our firm under applicable rules and regulations, including, but not limited to: maintaining your account log-in credentials on file; having the ability to change your address on record or ability to authorize distributions from your accounts; or authorization to open any new accounts on your behalf through the web-based platform. Financial Consulting Services Although Broadstreet does not provide broad based financial planning services outside of our wealth management service, we provide consulting services that focus on the specific needs and concerns of the client. Financial consulting services may include giving advice on investment and investment related matters. These services include the identification of financial goals and objectives, collection and assessment of all relevant data, identification of financial problems and formulation of solutions, and, if requested by the Client, the preparation of a plan in the form of specific written recommendations. The services we provide will typically focus on one or more of the following areas: Retirement Planning Retirement Planning is a process of determining retirement income goals and the actions and decisions necessary to achieve those goals. Retirement planning includes identifying sources of income, estimating expenses, implementing a savings program and managing assets. Future cash flows are estimated to determine if the retirement income goal will be achieved. Tax Planning The goal of tax planning is to arrange your financial affairs so as to minimize your taxes. There are three basic ways to reduce your taxes, and each basic method might have several variations. You can reduce your income, increase your deductions, and take advantage of tax credits. Investment Planning The goal of investment planning is to determine the investment mix and policy, matching investments to objectives, asset allocation for individuals and institutions, and balancing risk against performance. The process realizes strengths, weaknesses, opportunities and risks in the choice of debt vs. equity, domestic vs. international, growth vs. safety, and many other tradeoffs encountered in the attempt to maximize return at a given risk. Financial plans are based on your financial situation and the financial information you provide to our firm. If your financial situation, goals, objectives, or needs change, you must notify us promptly. You may choose to accept or reject our recommendations. If you decide to proceed with our recommendations, you may do so either through our firm or by using the advisory/brokerage firm of your choice. Important Note: Information related to tax and legal consequences that is provided as part of the financial plan is for informative purposes only. Clients are instructed to contact their tax or legal advisers for personalized advice Assets Under Management As of February 20, 2024, we provide continuous management services for approximately $102,684,067 in client assets managed on a discretionary basis.