A. Description of the Advisory Firm Waterstone Financial Advisory LLC (hereinafter “WFA”) is a Limited Liability Company organized in the State of Florida. The firm was formed in January 2023, and the principal owner is James Stuart Gallagher. Karly Ann Young is the firm’s chief compliance officer. B. Types of Advisory Services Investment Management Services WFA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. After reviewing your situation in depth, WFA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Clients are advised to promptly notify the firm if there are changes in their financial situation or investment objectives. If a client wishes to impose a reasonable restriction or mandate on the management of their accounts, it will be at WFA’s sole discretion, that the conditions will not materially influence the performance of a portfolio strategy or prove burdensome to its management efforts. WFA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of WFA’s economic, investment, or other financial interests. To meet its fiduciary obligations, WFA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios. It is WFA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Investment Management services can be provided by means of third-party managers, or by custom internal management defined as Advisor as Strategist: 1. Third Party Managers AssetMark Advisory Platform. – WFA has entered into a sub-advisory relationship with AssetMark, an investment adviser registered with the U.S. Securities and Exchange Commission. Through this relationship, clients can utilize the AssetMark investment platform to access various third-party investment solutions, including specialized tactical strategy portfolios, diversified baskets of exchange-traded funds, indexing mutual funds, portfolios of individual equity securities, or strategists specializing in other alternative styles. AssetMark provides WFA with research, due diligence, and a curated list of the various third-party managers that have been fully vetted, rated for their expertise, categorized for their trading style, and are monitored by the AssetMark investment team. WFA will remain responsible for determining the client’s investment objectives and whether one or more of the available managers is best suited to meet the designed investment objective of a specific account. The third-party strategist selected for an account is then responsible for the discretionary management of those assets. 2. Custom Management – Advisor as Strategist A client may choose to have a specific account managed in a way that cannot be provided by the diversified choices available through the AssetMark platform. This typically is driven by the clients desire to retain a certain set of equities or focus on an allocation that is a narrower in scope. The tax management of an account may also lead to a recommendation by WFA to enter into an Advisor as Strategist arrangement. The account is managed by WFA on a discretionary basis based on your financial situation, investment objectives, and risk tolerance. We actively monitor the account and make investment decisions regarding buying, selling, reinvesting, or holding securities, cash, or other investments. By the nature of potentially being less diversified, or having a narrower scope, these accounts may have a higher risk rating than a similar Third-Party Manager. This will be considered in the overall household risk planning and allocation. Financial Planning Financial plans and financial planning may include but are not limited to creating a structured income plan; developing savings targets; tax optimization; risk mitigation; wealth transfer strategies; college planning; and estate planning. Because investing involves varying degrees of risk, our advice will only be recommended

when consistent with a client’s stated investment objectives, risk tolerance, liquidity needs, and suitability. Financial Planning Services include the initial creation and formulation of a personal financial plan, with recommendations and comparative scenarios as necessary. It also includes the ongoing tracking of your progress in achieving the personal financial goals targeted in the plan. The scope of the financial planning is defined in advance and documented using a Financial Planning Agreement. Fees for Financial Planning Services are defined below under Item 5- Fees and Compensation. The Financial Planning process typically begins with the collection, organization, and assessment of relevant client data, including information concerning your lifestyle, risk tolerance, and cash flow, as well as the identification of your financial concerns, goals, and objectives. The primary objective of this process is to assist you in developing possible scenarios and a strategy for the successful management of income, assets, and liabilities. To help achieve this objective, we may provide education, explain the merit of possible solutions, as well as perform ongoing validation to the attainment of plan benchmarks. Services Limited to Specific Types of Investments WFA generally limits its investment advice to fixed income securities, equities, and ETFs. WFA may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we 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;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions WFA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by WFA on behalf of the client. WFA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent WFA from properly servicing the client account, or if the restrictions would require WFA to deviate from its standard suite of services, WFA reserves the right to end the relationship. D. Wrap Fee Programs WFA does not sponsor any wrap-fee programs. However, the AssetMark Platform includes “wrap fee” arrangements, meaning that if your assets are invested in an AssetMark Investment Solution, you will pay a fixed fee to AssetMark that includes the management fees, transaction costs, fund expenses, and other administration fees. AssetMark fees vary depending on which AssetMark Investment Solution or Sub- Advisor is applied to your account. Clients do not pay separate transaction fees for individual portfolio trades in the Account when their Account is invested in an AssetMark Investment Solution or another Sub-Advised Portfolio. The wrap fees may be higher or lower than if such services were obtained separately. Generally, wrap programs are relatively less expensive for actively traded accounts. Please see Item 14 for more details. Clients will sign an Account Set-up and Application Form to establish an account on that Platform and will receive the AssetMark Platform Disclosure Brochure describing the wrap program. E. Assets Under Management As of January 01, 2024, WFA has total assets under management of $174,121,647 of which are managed on a discretionary basis and $7,259,561 which are non-discretionary.