BridgePort Financial Solutions, LLC (also referred to as “BridgePort”, us, we, our and “Adviser” throughout this Disclosure Brochure) is a corporation formed under the laws of the State of Iowa. BridgePort is approved to conduct business in all fifty states and has office locations in many states. BridgePort is majority owned and controlled by Cambridge Investment Group, Inc., (“Cambridge”) which in turn is majority owned by the Schwartz Family Trust. Introduction Individuals licensed or approved as Investment Advisor Representatives (referred to as “Advisors” throughout this document) with BridgePort will provide its investment advisory services. These individuals are appropriately licensed when required, qualified, and authorized to provide advisory services on behalf of BridgePort. BridgePort registered as an Investment Adviser in 2023. Advisors are either employees of BridgePort or Cambridge or independent contractors of BridgePort. Advisors are restricted to providing services and charging fees in accordance with the descriptions detailed in this document. However, the exact services you will receive and the fees you will be charged are dependent upon your Advisor. Fees can also vary depending on the geographic location of our clients and/or Advisors. Advisors are instructed to consider the individual needs of each client when recommending an advisory platform. Advisors and BridgePort branch offices may use marketing names or other names that are held out to the public. Such names are known as “doing business as” names. The purpose of using a name other than BridgePort is for the Advisor to create a brand that is specific to the Advisor and/or branch, but separate from BridgePort. While BridgePort allows its Advisors to use a name other than BridgePort, the Advisor must disclose on advertising and client correspondence that advisory service are offered through BridgePort. General Description of Primary Advisory Services The following are descriptions of the primary services that Advisors are able to provide. A detailed description of each service available through BridgePort is provided in the corresponding sections of this brochure so that you can review the services and description of fees in a side-by-side manner. Financial Planning and Consulting Our Advisors may provide advisory services in the form of financial planning or consulting services. Financial planning and/or consulting services do not involve the active management of client accounts. Financial planning can be described as helping individuals determine and set their long-term financial goals through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Consulting services include consulting clients in the management of their money, investment options and asset reallocation. Consulting services can be narrow in scope and not take into consideration all areas of a client’s financial situation. If you decide to sign up for financial planning or consulting services you will be required to execute the appropriate BridgePort agreement. Upon execution of the agreement, your Advisor will provide verbal or written recommendations, depending on the investment advisory services selected and mutually agreed upon. Financial planning services will take into consideration either individually or a combination of information such as your objectives, overall financial situation, personal and financial goals, risk tolerance and objectives, risks that you are willing to undertake, investment knowledge, net worth, income, age, projected retirement, unusual or material funding requirements, inheritance possibilities, pensions social security, children/relative funding issues, estate issues, and living expenses expressed in today’s dollars requested for retirement. Based on the data and information compilation, financial planning recommendations are made based on your individual needs. Topics included as part of financial planning services provided can include, but are not limited to, one or more of the following:
• Portfolio Review and Evaluation P a g e | 6
• Retirement Account Analysis
• Cash Flow and Net Worth Analysis
• Risk Management Analysis
• Budgeting
• Planning for Family Member Special Needs
• Divorce Planning
• Developing a Comprehensive Documented Financial Plan
• Retirement Planning
• Education Funding Planning
• Review of Medical, Disability, and other insurance
• Estate Analysis and Planning
• Financial Planning and Education Seminars Advisors also provide financial planning services to business entities and groups requesting educational services and financial planning seminars or individual consulting and planning services to be provided to employees or members. If individual planning or consulting services will be provided, each participating employee or member will be required to execute a separate agreement with BridgePort depending on the services being provided. Advisors are allowed to provide financial planning seminars. Such services are provided on an impersonal basis, which means topics covered are general in nature and do not purport to focus on the individual needs of the seminar participants. Topics covered in a seminar can include the items listed above. Advisors charge a fee for participation in seminars. When fees charged are equal to or in excess of $500/per attendee, each attendee of the seminar will be provided a copy of this Disclosure Brochure. Financial planning services do not include the implementation of transactions on your behalf. To the extent you would like your Advisor to implement transactions on your behalf, you will need to contract with your Advisor for one or more of the management services described later in this section of the Disclosure Brochure. If you choose to utilize any of these services, a conflict of interest will exist between BridgePort, your Advisor and you. In addition to the fees charged for financial planning services, your Advisor will earn additional advisory fees for managed accounts. In addition to providing documented financial plans, Advisors provide investment consulting services. Consulting services are provided focusing on your specific areas of concern. These services can include retirement plan consulting services provided to an individual client seeking advice on how their retirement plan investments should be allocated. Advisors may also provide investment consulting services on accounts not managed or maintained by BridgePort. Only accounts for which a Advisor does not have trading authorization on the account are eligible for this service. Such accounts include, but are not limited to, 401(k) accounts and pension plan accounts not held at BridgePort. You will be responsible for all trade implementation under this service. Advisors will not have access to your funds, securities, or account(s) and therefore will not have authority to rebalance, reallocate or trade in the account(s). If you decide to sign up for this service, your selected accounts will be reviewed based upon your specific needs and desires for future financial goals and/or objectives. General or specific recommendations will be provided by your Advisor. Fees can be paid in a variety of options determined between yourself and your Advisor. Please see the Financial Planning and Consulting information within the Fees and Compensation section of this Disclosure Brochure for additional fee information. Financial Wellness Firms can contract with a Advisor to provide financial wellness and services to its employees through Financial Wellness Consulting. When working with the firm’s employees, Advisors provide various services such as assistance and education regarding budgeting and goal setting, financial wellness education presentations and personal financial wellness assessments. P a g e | 7 If you engage in Financial Wellness Services, you will be required to execute the appropriate BridgePort agreement. The exact services provided are pre-determined by the employer and further documented and agreed to in the appropriate BridgePort agreement. Upon execution of the agreement your Advisor will provide the services agreed upon in the agreement. Employers contract a Advisor to provide individualized recommendations or non-individualized services to employees. Services included in the individualized advice can include the following:
• Personal Financial Wellness Assessments
• Retirement Plan Participant Investment Advice The non-individualized (education) services can include the following:
• Assistance and Education Regarding Budgeting, Goal Setting and Savings Tools.
• Financial Wellness Education Services Investment Management Services Advisors can provide advisory services in the form of investment management services. Investment management services involve providing clients with continuous and ongoing supervision over client account(s). This means that Advisors continuously monitor a client’s account(s) and make trades in the account(s) when necessary. Investment management services are provided through one or more of the following platforms: ➢ BridgePort Advisory Platform ➢ BridgePort Retirement Plan Strategies Management Platform ➢ Retirement Plan Advisory and Consulting Services ➢ Recommendation of Unaffiliated Third Party Investment Adviser ➢ Annuities For all programs, account recommendations are ultimately determined based upon your risk tolerance, financial situation, and stated investment objectives (i.e. preservation of capital, income, growth and income, growth and speculation, etc.). All information gathered from you is confidential in accordance with BridgePort’s Privacy Policy. While BridgePort does not set a specific timeframe for review, it does encourage Advisors to contact all of their clients at least annually, or at your (the client’s) request, to discuss your investment portfolio and to update your financial information should any changes have occurred. It is necessary for you to inform your Advisor promptly with respect to any changes in your financial situation or investment goals and objectives. Failure to notify BridgePort of any such changes could result in investment recommendations not meeting your needs. Your Advisor can provide investment advice to you regarding your retirement plan account or individual retirement account (“IRA”). In doing so, your Advisor must act as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary responsibility requires that Advisors put your interests ahead of their own. In acting in your best interest your Advisor will adhere to consumer protection standards that require that compensation not be excessive based on the market value of the particular services, rights and benefits delivered to you. Recommendations made by your Advisor regarding rollover options, from a retirement plan to another plan or IRA, from an IRA to a plan, from an IRA to another IRA or from one account type to another (e.g., commission-based to fee-based), will require your Advisor to document the reasons for the recommendation and specify why the recommendation is in your best interest. The way that your Advisor and BridgePort make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest; P a g e | 8
• Charge no more than is reasonable for services; and
• Give you basic information about conflicts of interest. You should discuss with your Advisor the costs and benefits of each Investment management service and then select the one that you believe best supports your investment goals and style and provides the most cost-effective means of executing your investment strategy. More details regarding the brokerage options are available in the Brokerage Practices section of this Disclosure Brochure. BridgePort Advisory Platform Advisors provide investment management services defined as giving continuous investment advice to you and making investments based on your individual needs through accounts established at an institutional RIA. Through the BridgePort Advisory Platform, your Advisor will be responsible for determining investment recommendations and implementing transactions. The Advisor shall manage your account(s) in accordance with your individual needs, objectives and risk tolerance. These accounts are managed on either a discretionary trading basis or a non-discretionary trading basis as agreed to by you and your Advisor. In order to have trading authorization on your account(s) your Advisor must be granted limited power of attorney over the account(s). BridgePort has a number of approved custodians. While there are others, the most commonly used will be Schwab Advisor Services, TD Ameritrade Institutional, Fidelity Brokerage Services LLC and Pershing Advisor Solutions. BridgePort is independently owned and operated and not affiliated with any of these companies. Generally, a Advisor will not use every platform and in most cases will only recommend the use of one. More details regarding the brokerage options are available in the Brokerage Practices section of this Disclosure Brochure. Models and strategies used by one Advisor can be different than strategies used by other Advisors. Some Advisors limit their advice to mutual funds and others will provide advice on a full range of securities that include but are not limited to equities, mutual funds, options, fixed income and alternative investments. Some Advisors develop models or strategies that are generally applied across their clients while other Advisors will develop truly individualized portfolios for each client. ➢ Retirement Plan Advisory and Consulting Services BridgePort provides investment advisory services to retirement plans, which consists of services offered through BridgePort’s Advisory Platform or appropriate general consulting services. The Advisor and Plan Sponsor will outline the services provided through the BridgePort Retirement Agreement. The services provided, among others that are outlined specifically in the agreement entered into with you, are summarized below. ▪ Description of Non-Discretionary Investment Advisory Services The following non-discretionary investment advisory services are provided by BridgePort acting as a fiduciary within the meaning of section 3(21) (B) (ii) of ERISA, if the Plan is subject to ERISA. ⬧ Recommendations to establish or revise the plan’s Investment Policy Statement (“IPS”): Advisor will review with the Plan Fiduciary the investment objectives, risk tolerance and goals of the Plan. If the Plan does not have an IPS, the Advisor will recommend investment policies to assist the Plan Fiduciary to establish an appropriate IPS. If the Plan has an existing IPS, Advisor will review it for consistency with the Plan’s objectives. If the IPS does not represent the objectives of the Plan, Advisor will recommend to the Plan Fiduciary revisions that will establish investment policies that are congruent with the Plan’s objectives. ⬧ Recommendations to select and monitor the Designated Investment Alternatives (“DIAs”): Based on the Plan’s IPS or other guidelines established by the Plan, Advisor will review investment options available to the Plan and will make recommendations to assist the Plan Fiduciary to select the DIA to be offered to Plan participants. Once the Plan Fiduciary selects the DIAs, Advisor will, on a periodic basis and/or upon reasonable request, provide reports, information and recommendations to assist the Plan Fiduciary to monitor the investments. If the IPS criteria will require an investment to be removed, Advisor will provide information, analysis and recommendations to the Plan Fiduciary to help evaluate replacing investment alternatives. P a g e | 9 ⬧ Recommendations to select and monitor Qualified Default Investment Alternatives (“QDIAs”): Based on the Plan’s IPS or other guidelines established by the Plan, Advisor will review the investment options available to the Plan and will make recommendations to assist the Plan Fiduciary to select the Plan’s QDIAs for Plan participants that fail to direct the investment of their account(s). Once the Plan Fiduciary selects the QDIAs, Advisor will provide reports, information and recommendations, on a quarterly or upon reasonably requested basis, to assist the Plan Fiduciary to monitor the investments. If the IPS criteria require an investment to be removed, Advisor will provide information and analysis to assist the Plan Fiduciary to evaluate replacement investment alternatives. ⬧ Recommendations to allocate and rebalance Model Asset Allocation Portfolios (“Model Portfolios”): Based on the Plan’s IPS or other investment guidelines established by the Plan, Advisor will review the investment options available to the Plan and will make recommendations to assist the Plan Fiduciary to create and maintain Model Portfolios. Once the Plan Fiduciary approves the Model Portfolios, the Advisor will provide reports, information and recommendations, on a periodic basis, designed to assist the Plan Fiduciary to monitor the Plan’s investments. If the IPS criteria require an investment to be removed, the Advisor will provide information and analysis to assist the Plan Fiduciary to evaluate replacement investment alternatives to be included in the Model Portfolios. Upon reasonable request the Advisor will make recommendations to the Plan Fiduciary to rebalance the Model Portfolios to maintain their desired allocations. ⬧ Recommendations to select and monitor Investment Managers: Based on the Plan’s IPS or other guidelines established by the Plan, Advisor will review the potential Investment Managers available to the Plan and will make recommendations to assist the Plan Fiduciary to select one or more Investment Manager. Once the Plan Fiduciary approves the Investment Manager, the Advisor will provide, on a periodic basis, reports, information and recommendations to assist the Plan Fiduciary to monitor the Plan’s Investment Managers. If the IPS criteria require an Investment Manger to be removed, the Advisor will provide information and analysis to assist the Plan Fiduciary to evaluate replacement Investment Managers. ▪ Description of Plan Non-Fiduciary Services The following investment education services are provided by BridgePort acting in a non-fiduciary capacity. ⬧ Assistance with Plan Fiduciaries’ governance and committee review, including:  Determining plan objective and plan design options  Reviewing Retirement Plan Committee structure and requirements  Reviewing participant education and communication strategy, including ERISA 404(c) requirements  Coordinating and reconciling participant disclosures under ERISA Rule 404(a)(5) and developing requirements for responding to participant requests for additional information  Developing and maintaining a fiduciary audit file  Attending periodic meetings with Plan Fiduciary (upon request by Plan Fiduciary) ⬧ Assistance with Plan Fiduciaries’ vend management (service provider selection/review), including:  Reviewing fees and services and identifying procedures to track the receipt and evaluation of ERISA 408(b)(2) disclosures  Providing periodic benchmarking of fees and services to assist review for reasonableness  Reviewing ERISA spending accounts or Plan Expense Recapture Accounts (PERAs)  Generating and evaluating service provider Requests for Proposals (RFPs) and/or Requests for Information (RFIs)  Support with contract negotiations – Note: Advisors do not provide legal advice.  Service provider transition and/or plan conversion ⬧ Investment Education for Plan Fiduciaries Concerning:  Investment Policy Statements  Assessment of overall investment structure of the

Plan (i.e., types and number of asset classes, model portfolios, etc.)  Review of the Plan’s investment options P a g e | 10  Review of Qualified Designated Investment Alternatives (QDIAs)  Search and review of investment managers ▪ Description of Plan Participant Non-Fiduciary Services The following investment education services are provided by BridgePort acting in a non-fiduciary to plan participants. ⬧ Providing group enrollment and investment education meeting ⬧ Providing fee specific education and communicate the Plan’s requirements for requesting additional information about plan fees and expenses ⬧ Supporting individual participant questions ⬧ Providing periodic updates upon request or through newsletter ⬧ Assisting participants with retirement readiness ▪ Description of Discretionary Investment Management Services In certain circumstances, services are provided by BridgePort acting as a fiduciary within the meaning of section 3(38) of ERISA, if the Plan is subject to ERISA, including the following: ⬧ Initial selection and ongoing monitoring of the Plan’s Designated Investments ⬧ Review the Plan’s investment objectives, risk tolerance and goals with the Plan committee. If the Plan does not have an IPS, Advisor will recommend investment policies to assist the Plan Committee with establishing investment objectives. If the Plan has an existing IPS, Advisor will review it for consistency with the Plan’s objectives and recommend revisions to the Plan Committee to establish investment policies that are congruent with the Plan’s objectives. ⬧ Review the investment options available to the Plan and will utilize qualitative and quantitative analysis to provide the Plan Sponsor with recommendations regarding the Plan’s Designated Investments that meet the criteria set forth in the stated investment objectives. ⬧ Once Advisor’s initial recommendations have been implemented, the Advisor will continue to monitor the Designated Investments and instruct the Platform Provider directly to remove and replace investments that no longer meet the IPS criteria or investment objective criteria. Advisor will communicate any changes to the Plan Sponsor reasonably in advance of the proposed change. Plan Sponsor understands that declining any of Advisor’s recommendations can cause the services under the BridgePort Retirement Plan Agreement to terminate.  Qualified Default Investment Alternative Management: o If the Plan has an existing QDIA, Advisor will map those participant accounts to Advisor’s Moderate Model Portfolio and will serve as the Plan’s QDIA Manager with respect to participant accounts that are automatically defaulted into the Model Portfolios pursuant to ERISA section 404(c)(5). For new plans or those that did not previously designate a QDIA, the Plan Sponsor authorizes Advisor to designate its Moderate Model Portfolio as the Plan’s QDIA, and any participant who fails to direct the investment of their account(s) will automatically be invested in the Moderate Model Portfolio. Plan Sponsor, however, retains the sole responsibility to provide all notices to participants as required under ERISA section 404(c), including 404(c)(5).  Creation and Maintenance of Model Asset Allocation Portfolios (“Model Portfolios”): o BridgePort will create risk-based Model Portfolios to be offered to Plan participants through the Platform Provider’s platform. o The Model Portfolios will be constructed with the goal of achieving varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures offered through investment alternatives available through the Plan. Advisor will diversify, reallocate and rebalance the Model Portfolios and associated risk levels over time in accordance with generally accepted investment theories and in compliance with the Plan’s IPS. Advisor will make changes to the underlying investment and/or the asset allocation percentage of the Model Portfolios and will communication such instructions directly to the Platform Provider. Advisor will communicate any changes to the Plan Sponsor reasonably in advance of the proposed change. P a g e | 11 The Advisor will not be responsible for selection or monitoring, and will not make any recommendations to retain or remove, employer stock or investment options beyond the Designated Investments (i.e., stable value funds, target date portfolios, mutual fund or brokerage windows, guaranteed investment contracts, unallocated accounts, etc.). From time to time BridgePort and/or Advisors can make the Plan or Plan participants aware of, and offer services available, from BridgePort and/or Advisors that are separate and apart from the retirement plan advisory and consulting services described above. In offering any such services, neither BridgePort nor its Advisors providing the services are acting as a fiduciary under ERISA with respect to such offering of services. If any such separate services are offered to you as the client, you will make an independent assessment of such services without reliance on the advice or judgment of BridgePort or the Advisor. Special considerations for some of the retirement plan programs listed above are in place. Those considerations are listed below:
• Security Financial Resources, Inc. Security Financial Resources, Inc. (“SFR”) provides management of model portfolios for retirement plans and their participants. SFR serves as the record keeper and will deduct advisory fees from your account.
• Tax Exempt Marketplace Program Some Advisors provide services to employees of public-school systems and tax-exempt organizations that qualify under section 501(c)(3) of the Internal Revenue Code. BridgePort’s Tax Exempt Marketplace Program (“TEMP”) is designed for Advisors to provide services to clients who have available to them, through their organization, retirement accounts held in an Optional Retirement Plan or also known as 401(a), 403(b) and 457 accounts. Advisors can provide these services either by the Advisor providing the investment management services or utilizing the services of third party investment advisers (recommendation of third party investment advisers). BridgePort accounts are custodied at Fidelity Brokerage Services, LLC on its Tax Exempt Services (Fidelity TEM) platform or at TIAA. Advisors will generally use both custodians as this is determined independently by each organization. ➢ Recommendation of Unaffiliated Third Party Investment Advisers Advisors can provide advisory services by referring clients to outside, or unaffiliated, investment advisers that are registered or exempt from registration as investment advisers. Third party investment advisers recommended by BridgePort or a Advisor must pass the BridgePort due diligence process and be approved by BridgePort. BridgePort enters into the relationship with third party investment advisers and as a result, BridgePort and your Advisor receive a portion of the fee charged and collected by the third party investment adviser. The responsibility for activities in this type of account(s) varies based on the BridgePort agreement with the Third Party Investment Adviser. A conflict of interest is created in this situation as your Advisor will only be offering those third party investment advisers that have met the conditions of the BridgePort due diligence review and have agreed to pay a portion of their advisory fee to BridgePort. There could be other third party investment adviser programs suitable for you that are more or less costly. No guarantees can be made that your financial goals or objectives will be achieved. Further, no guarantees of performance can be offered. Your Advisor will provide asset allocation advice through solicitor, co-advisor, and sub-advisor programs based on your individual, personal and financial goals, investment objectives, and risk tolerance. The following information provides a brief description of each of these programs. ▪ Third Party Investment Adviser Solicitor Program BridgePort provides promoter (or also referred to as solicitor) services by recommending a program sponsor who is an unaffiliated third party investment adviser who shall provide asset management services. Clients will enter into an agreement directly with the unaffiliated third party investment adviser. Your Advisor will assist you in selecting a suitable investment portfolio and asset allocation strategy that will be used by the program sponsor to properly allocate your assets in the investment portfolio. Your Advisor will provide initial and ongoing education concerning the asset allocation strategy selected by you. Advisors are available to answer questions you may have regarding your P a g e | 12 account and act as your relationship manager between you and the third party investment adviser. Your Advisor will periodically meet with you to discuss changes in your investment objectives and risk tolerance, and current asset allocations within each portfolio. The third party investment adviser periodically changes the relative allocations among securities in the portfolios. Third party investment advisers will generally take discretionary authority to determine the securities to be purchased and sold for you. BridgePort and its associated persons do not have trading authority with respect to a client’s managed account(s) with the third party investment adviser(s). Advisors can only change the selected asset allocation strategy with your consent. ▪ Third Party Investment Adviser Co-Advisor Program BridgePort provides services as a co-advisor by recommending a program sponsor who is an unaffiliated third party investment adviser who shall provide asset management services. Clients will enter into an agreement directly with the unaffiliated third party investment adviser. Your Advisor will assist you or select a suitable investment portfolio and asset allocation strategy that will be used by the program sponsor to properly allocate your assets in the investment portfolio. Your Advisor will provide initial and ongoing education concerning the asset allocation strategy selected. Advisors are available to answer questions you may have regarding your account and act as your relationship manager between you and the third party investment adviser. Your Advisor will periodically meet with you to discuss changes in your investment objectives and risk tolerance, and current asset allocations within each portfolio. The third party investment adviser periodically changes the relative allocations among securities in the portfolios. Third party investment advisers will generally take discretionary authority to determine the securities to be purchased and sold for you. You are able to give your Advisor discretion on certain activities such as moving among strategies and/or multiple managers. ▪ Third Party Investment Adviser Multi-Managed Program BridgePort can recommend an unaffiliated third party investment adviser to provide asset management services through a platform offered by multiple third party investment advisers or custodians. Clients will typically enter into an agreement directly with both the unaffiliated third party investment adviser and BridgePort and appoint BridgePort as their Investment Adviser on the account. You and your Advisor will select an investment portfolio and asset allocation strategy that will be used by the Sub-advisor to properly allocate your assets in the investment portfolio. Your Advisor will provide initial and ongoing education concerning the asset allocation strategy selected by you. Your Advisor will periodically meet with you to discuss changes in your investment objective and risk tolerance, and current asset allocations within each portfolio. The Sub-advisor periodically changes the relative allocations among securities in the portfolios. Clients participating in a sub-advisory account will grant BridgePort discretionary authority with respect to investment and advisory services. When the third party investment adviser is used to make investment selections, the client must also grant the third party investment adviser full discretionary authority. Discretionary trading authority allows the Advisor and/or third party investment adviser to (i) invest and reinvest the assets in this program and/or (ii) retain Sub- advisors with respect to all or part of the Separate Account Program Assets. When Sub-advisors are selected, they will also be granted full discretionary authority to invest and reinvest with respect to which such Sub-advisors have been granted investment discretion, subject to reasonable restrictions requested by you. ➢ Annuities BridgePort offers investment management services for various approved annuities. Advisors can manage the sub-accounts of those annuities either on a discretionary or non-discretionary basis. Your Advisor will provide ongoing investment advice based on your investment objectives, risk tolerance, options available under the annuity contract, and any other benefits and features under the annuity contract. A conflict of interest is present as your Advisor receives a fee for the advice provided to you, however, not all annuity products are approved for investment management services. There could be other annuity products suitable for you that are more or less costly. P a g e | 13 Specialization Investment strategies and philosophies differ among Advisors who are responsible for determining and implementing their own investment advice under the supervision and compliance controls of BridgePort. BridgePort does not consider itself as specializing in any one form of advisory service. Limits Advice to Certain Types of Investments With some exceptions, Advisors are available to offer advice on most types of investments owned by a client and, at the specific request of a client, will explore investment options not currently owned by a client. However, Advisors are not permitted to provide advice on futures or commodity contracts with the exception of managed futures or structured products approved by BridgePort. It is also required that Third Party Managers used by Advisors be approved by BridgePort. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of each individual client. Clients are given the ability to impose restrictions on their accounts including specific investment selections and sectors. Portfolio Management Program Fee Overview As described in greater detail in the section entitled “Fees and Compensation,” Advisors provide asset management services through traditional management programs, including the BridgePort Advisory Platform, in which there are two separate types of fees: (i) an investment advisory fee for our advisory services; and (ii) a transaction “ticket charge” fee for each transaction (i.e., buy/sell/exchange) by the qualified custodian of your account. Your Advisor determines whether or not the ticket charges imposed by the custodian are charged to you or the Advisor. If your Advisor chooses to absorb and pay the ticket charges a conflict of interest is created in that your Advisor could choose to trade less often in order to reduce their trading expenses. BridgePort does not receive ticket charge compensation when transactions occur at another qualified custodian such as Schwab, TD Ameritrade or Fidelity. For information on additional fees regarding ticket charges, please refer to the Fees and Compensation section of this Brochure. Client Assets Managed by BridgePort As a newly formed SEC-registered adviser in 2023, BridgePort did not have any assets under management in 2022. Business Continuity Plan BridgePort has established a Business Continuity Plan (BCP). The BCP describes how it responds to significant business disruption and provide investors with alternative contact information in the event of a significant business disruption. The Business Continuity Summary is available upon written request. General Disclosure Regarding ERISA and Qualified Accounts The following disclosure is directed for clients of BridgePort that are (i) a pension or other qualified employee benefit plan (including a 401(k) plan) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”); (ii) a tax-qualified retirement plan under section 401(a) of the Internal Revenue Code of 1986, as amended (the “Code”), and not covered by ERISA; or (iii) an individual retirement account (“IRA”) under Section 408 of the Code. It is your responsibility to ensure BridgePort and your Advisor have been furnished complete copies of all documents that establish and govern the plan and evidences authority to retain BridgePort as an investment adviser. You must promptly furnish to BridgePort any amendments to the plan and if any amendment affects the right or obligations of BridgePort, such amendment shall be binding on BridgePort and the Advisor only when agreed to by BridgePort and the Advisor in writing. BridgePort must maintain appropriate ERISA bonding coverage for their managed accounts(s) and must include within the coverage of the bond BridgePort, Advisor and their personnel as required by law. When managing accounts, 12b-1 (marketing and distribution) fees and trail earned will be credited to your account at the clearing firm whenever possible. When 12b-1 fees and trails received are not credited to your account, the investment P a g e | 14 advisory fee will be lowered, or offset by the amount paid to BridgePort. Advisors are required to provide a 408(b)(2) disclosure for all group retirement plans governed by ERISA, excluding owner-only retirement plans. The BridgePort 408(b)(2) disclosure will outline the service provided by the Advisor, fiduciary status, any direct or indirect compensation received by BridgePort, and manner of compensation receipt. An updated fee disclosure will be provided in the event of a change to the advisory fees received or services provided to the plan. General Disclosure for No Transaction Fee (“NTF”) Programs Schwab, TDA and FIWS offer select mutual funds to be purchased by you with no transaction fees (“NTF Shares”). Schwab, TDA and FIWS receive revenue directly from the mutual fund companies that support NTF programs by making their funds available through the NTF Program. As the name suggests, you do not pay a transaction charge when buying or selling NTF shares. The NTF Shares can be more expensive to you over time because of the higher ongoing internal operating expenses, such as 12b-1 fees. Mutual funds not offered through the NTF Program are referred to as transaction fee funds, for which you pay a higher transaction or ticket charge compared to NTF Shares; however, the transaction fee funds can be less expensive to you over time because of lower ongoing operating expenses. You and your Advisor should discuss and understand these additional indirect expenses borne as a result of the mutual fund fees. Restrictions apply in certain situations. Termination Please keep in mind that we have the right to refuse any Agreement submitted for approval. If the appropriate disclosure statement (i.e., this document or a separate written disclosure statement containing the same information as this document) is not delivered to you at least 48 hours prior to entering into a Program Agreement, you have the right to terminate services without penalty (i.e., full refund of all fees paid in advance or in the event fees are billed in arrears, no fees shall be due) within five (5) business days after entering into the Agreement. For purposes of this provision, an Agreement is considered entered into when all parties have executed the Agreement. All services continue in effect until terminated by either party (i.e., you, your Advisor, or BridgePort) by giving notice to the other party. Written notice of at least 30 days is required for investment management programs unless all parties mutually agree on an earlier termination date. Any prepaid, unearned fees are promptly refunded to you. If termination of the Program Agreement occurs after five (5) days from account opening, we may retain up to $500 of the prepaid Account Fee for the current quarter. Fee refunds will be determined on a pro rata basis using the number of days services are actually provided during the final period. Fee refunds calculated to be less than $25 generally will not be processed. Upon actual receipt of notice of termination, our obligation to manage or advise you with respect to the account immediately terminates. This means that unless we receive instructions from you, we will not buy, sell, reallocate, or rebalance Funds in the account. IRA and 403(b)(7) accounts remain subject to the provisions and restrictions of regulations, law and the custodial Agreement. Termination of the Agreement does not affect the liabilities or obligations of the parties from transactions initiated prior to termination. For those clients utilizing third party investment advisers, termination procedures are determined by the individual third party investment adviser. Please refer to the specific third party investment adviser’s disclosure brochure for specific termination procedures.