A. Firm Information Balanced Rock Investment Advisors LLC (referred to as “BRIA”, the “Advisor”, “we”, “our”, “us”) is a Registered Investment Adviser with the SEC, which is organized as a Limited Liability Company (LLC) under the laws of the State of Massachusetts. BRIA was founded in March 2011, and is owned and operated by its President, Daniel M. Flannery, CFA. Thomas Higgins, Jr. serves as Chief Compliance Officer. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by BRIA. BRIA is proud to be a fee-only investment advisor, which means we are only compensated directly by our Clients. Neither BRIA nor any of its officers or employees receives any share of commissions, sales charges, marketing fees, custody fees, administrative fees, or referral fees from any third parties. We are a fiduciary, which means that we always act in the best interest of our Clients, putting their interests ahead of our own. Any potential or active conflicts of interest are disclosed, and we take steps to minimize those conflicts. Our goal is to provide high quality, reasonably priced and completely transparent financial advice and investment management, while maintaining the highest standards of ethics. 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. B. Advisory Services Offered BRIA offers fee-only wealth management and investment advisory services to individuals, families, retirement plans, trusts, estates, and businesses in Massachusetts and other states (each referred to as a “Client” or “You”). These services are provided pursuant to written Wealth Management Agreements, Financial Planning Agreements, and Consulting Agreements (collectively “Investment Advisory Agreement(s)”). Wealth Management Services BRIA offers comprehensive Wealth Management to Clients pursuant to a Wealth Management Agreement. Wealth Management includes comprehensive Financial Planning Services and Investment Management Services, development of an Investment Policy Statement, and other advisory services, including assistance with tax, estate planning, and insurance needs. BRIA may perform an evaluation to assess the need for insurance and assist in the acquisition of insurance. In addition, the Advisor may coordinate with attorneys to develop an estate plan and work with accountants for tax planning and the preparation of tax returns. There is an portfolio minimum of $300,000, which may be waived by BRIA in its discretion. BRIA generally offers wealth management services only to clients with more than $300,000 in total portfolio assets. Wealth Management includes customized Investment Management services. This is achieved through ongoing personal Client contact and interaction while providing discretionary or non-discretionary investment management and planning services. BRIA works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. BRIA will then pg. 5 construct a portfolio intended to meet Client portfolio goals. In some instances, BRIA will manage client assets pursuant to an investment model developed and implemented by BRIA. In all instances in which client assets are managed within a BRIA model, BRIA will ensure that the risk/return objective of the model aligns with the risk tolerance and investment objectives of the client. Once we select a model 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 in your financial circumstances. BRIA’s investment strategy seeks broad diversification and is 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. BRIA will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, restraints, and risk tolerance agreed to by the Client in the Investment Policy Statement. 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. BRIA evaluates and selects investments for inclusion in Client portfolios only after applying our internal due diligence process. BRIA may, on occasion, rebalance or change investment allocations of the portfolio. BRIA may increase or decrease allocations to specific positions to adjust security, sector or asset class weightings. The Advisor may employ cash positions as a possible hedge against market movement, which may adversely affect the portfolio. BRIA may buy or sell positions for reasons that include, but are not limited to, harvesting capital gains or losses, adjusting business or sector risk exposure to a specific security or class of securities, valuation or weighting of the positions in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or to avoid any perceived risk deemed unacceptable for the Client’s risk tolerance. If any of the actions BRIA considers taking are contrary to the Client’s Investment Advisory Agreement or Investment Policy Statement, we will obtain the prior written approval of the Client before implementing them. Prior to rendering investment advisory services, BRIA will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objective[s]. Each Client engagement is customized based on the needs of the Client and the terms of the engagement are detailed in the Wealth Management Agreement. BRIA provides wealth management services and does not provide custodial or other administrative services. At no time does BRIA accept or maintain physical custody of a Client’s funds or securities. All Client assets are managed within their designated account, at a qualified custodian unaffiliated with BRIA, pursuant to the Client’s Investment Advisory Agreement. Please review Item 15 – Custody for more information. No guarantees can be made that a client’s financial goals or objectives will be achieved by us or by recommendations of BRIA. Further, no guarantees of performance can ever be offered by the Firm. Financial Planning and Consulting Services BRIA offers a variety of Financial Planning and Consulting Services to Clients, pursuant to a Financial Planning Agreement or Consulting Agreement. Services are offered in a number of areas depending on the type

of Client, their constraints, objectives and financial situation. BRIA generally offers hourly financial planning services only to clients who have less than $300,000 in total portfolio assets. This may be waived at the discretion of BRIA. Generally, such services involve preparing a financial plan or rendering a financial consultation for Clients based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, insurance needs assessment, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter pg. 6 retirement savings, or establish education savings and/or charitable giving programs. BRIA may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning or consulting engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For certain consulting or ad-hoc engagements, the Advisor may not provide a written summary. This will be disclosed in the Investment Advisory Agreement. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. An expected time frame for completion of a specific plan or consultation will generally be agreed to in advance by the Advisor and the Client and included in the Investment Advisory Agreement. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effect the transaction through the Advisor. Financial Planning and Consulting Services are not offered on a discretionary basis. DIAL-In Strategy Services BRIA helps Financial Planning and Wealth Management Clients make direct investments that are outside of BRIA’s discretionary management through the DIAL-In service, described in more detail in Item 8 below. BRIA does not make these investments on behalf of our Clients, rather BRIA advises and assists Clients with these investments and reports to Clients on them. Clients sign all investment documentation themselves, approve, and complete all purchases themselves. BRIA presents DIAL-In research reports to clients, and if the client chooses to invest, BRIA charges an ongoing fee for Wealth Management clients based on the amount of the initial amount invested or hourly fees for Financial Planning Clients. See Item 5 below for the fees related to the DIAL-In service. C. Client Account Management Prior to engaging BRIA to provide investment advisory services, each Client is required to enter into an Investment Advisory Agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Client Inquiry and Establishing an Investment Policy Statement – BRIA, in connection with the Client, will develop a statement that summarizes the Client’s investment goals and objectives along with the strategy to be employed to meet the objectives. An Investment Policy Statement generally includes specific information on the Client’s stated goals, time horizon for achieving those goals, investment strategy, financial situation, tax and legal situation, risk tolerance and any restrictions imposed by the Client.
• Financial Planning – BRIA will develop a plan for saving, investing and addressing any other financial needs and concerns.
• Asset Allocation – BRIA will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – BRIA will develop a portfolio for the Client, consistent with the Client’s strategic asset allocation that is intended to meet the stated constraints and objectives of the Client. Investment Management and Supervision – BRIA will provide investment management and ongoing oversight of the Client’s accounts and overall portfolio, in accordance with the IPS and Investment Advisory Agreement. BRIA’s investment management services are always provided based on your individual needs. BRIA will not enter into an advisory relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client may impose reasonable restrictions on investing in pg. 7 certain asset classes or any specific types of securities by advising their investment adviser representative of such restrictions. D. Wrap Fee Programs A “wrap fee program” is an investment management structure whereby the client pays a single fee for investment management and the execution of transactions in the client’s account. BRIA does not sponsor or participate in a wrap fee program. Investment management services are provided directly by BRIA. E. Retirement Plan Rollovers 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. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we are asked by a client or prospective client to make a recommendation from among these choices, we have a conflict of interest in that we have an incentive to recommend that a client roll over their retirement plan assets into an account to be managed by the Firm. Such a recommendation creates a conflict of interest as we will earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to accept our recommendation or to roll over retirement plan assets to an account managed by us. F. Assets Under Management BRIA has the following assets under management as of December 31, 2023: Discretionary Assets Under Management: $ 137,642,490 Non-Discretionary Assets Under Management: $0 Total Regulatory Assets Under Management: $137,642,490