Item 5 - Additional Compensation .......................................................................................................................... 25 Item 6 - Supervision ..................................................................................................................................................... 25 Item 7 - Requirements for State-Registered Advisors ................................................................................... 25 Firm Description Breachway Investments LLC (“Breachway Investments”) was founded in 2019 as a limited liability company formed under the laws of the State of Delaware and has been in business as an investment adviser since that time. Joseph Curran is 100% owner. Types of Advisory Services ASSET MANAGEMENT Breachway Investments offers discretionary and non-discretionary asset management services to advisory Clients. Breachway Investments will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Discretionary When the Client provides Breachway Investments discretionary authority the Client will sign a limited trading authorization or equivalent. Breachway Investments will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-Discretionary When the Client elects to use Breachway Investments on a non-discretionary basis, Breachway Investments will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, Breachway Investments will obtain prior Client approval on each and every transaction before executing any transaction. ERISA PLAN SERVICES Breachway Investments provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation plans. Breachway Investments may act as a 3(21) advisor: Limited Scope ERISA 3(21) Fiduciary. Breachway Investments may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor Breachway Investments has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Breachway Investments can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. Breachway Investments acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing

periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands Breachway Investments’ assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Breachway Investments is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Breachway Investments may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. 3. Breachway Investments has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to Breachway Investments on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, a thorough review of all applicable topics including but not limited to, Retirement Planning, Succession Planning, Education Planning, Legacy Planning, Insurance Planning, Investment Planning, Budget Planning, Tax Planning, Major Purchase Planning, Divorce Planning, Debt Management Planning, Business Exit Planning, and Cash Flow Analysis will be reviewed. If a conflict of interest exists between the interests of Breachway Investments and the interests of the Client, the Client is under no obligation to act upon Breachway Investments’ recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through Breachway Investments. Financial plans will be completed and delivered inside of thirty (30) days contingent upon timely delivery of all required documentation. SEMINARS AND WORKSHOPS Breachway Investments holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs Breachway Investments does not sponsor any wrap fee programs. Client Assets under Management Breachway has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $102,582,347 $3,069,075 09/12/2023