High Point Wealth was founded in 2008 with a mission to provide independent, high quality financial planning and investment advisory services. Bradford Gruby is the principal owner of High Point Wealth. As of January 2, 2024, High Point Wealth had $127,664,590 in assets under management, all of which was managed on a discretionary basis. Prior to engaging High Point Wealth to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with High Point Wealth setting forth the terms and conditions under which High Point Wealth renders its services (collectively the “Agreement”). Neither High Point Wealth nor the client may assign the Agreement without the consent of the other party. A transaction that does not result in a change of actual control or management of High Point Wealth is not considered an assignment. This disclosure brochure describes the business of High Point Wealth. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of High Point Wealth’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on High Point Wealth’s behalf and is subject to High Point Wealth’s supervision or control. Financial Planning and Consulting Services High Point Wealth provides its clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment related matters). These services are tailored to the needs of the client, but generally place an emphasis on retirement planning and college expense planning. In most cases, the financial planning services are bundled together with Investment Management services described below. The fees for these services are bundled as part of Investment Management Fees described in Section 5. In performing its services, High Point Wealth is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. When appropriate, High Point Wealth will recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a potential conflict of interest exists when High Point Wealth recommends its own additional services to a client. High Point Wealth always endeavors to act in the best interest of each of its clients. The client is under no obligation to act upon any of the recommendations made by High Point Wealth under a financial planning or consulting engagement or to engage the services of any such recommended professional, including High Point Wealth itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of High Point Wealth’s recommendations. Clients are advised that it remains their responsibility to promptly notify High Point Wealth if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising High Point Wealth’s previous recommendations and/or services. Investment Management Services Clients can engage High Point Wealth to manage all or a portion of their assets on a discretionary or non- discretionary basis. High Point Wealth primarily allocates clients’ investment management assets among mutual funds, exchange-

traded funds (ETFs), index funds, and individual debt and equity securities in accordance with the investment objectives of the client. High Point Wealth also provides advice about any type of investment or legacy position otherwise held in clients' portfolios. High Point Wealth upon request renders non-discretionary investment management services to clients relative to variable life/annuity products that they own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that are not held by the client’s primary custodian. In so doing, High Point Wealth either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. High Point Wealth tailors its advisory services to the individual needs of clients. High Point Wealth consults with clients initially and on an ongoing basis to provide Investment Management services, and offers Financial Planning which evaluates risk tolerance, time horizon and other factors that may impact the clients’ investment needs. High Point Wealth seeks to ensure that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify High Point Wealth if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon High Point Wealth’s management services. When we provide investment advice to clients regarding retirement plan accounts or individual retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with client interests, so we operate under a special rule that requires us to act in our clients’ best interest and not put our interest ahead of theirs. 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 clients’ 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 our clients’ best interest;
• Charge no more than is reasonable for our services; and
• Give clients basic information about conflicts of interest. When providing recommendations to retirement plan accounts involving rollover considerations, there are generally four options regarding an existing retirement plan account. An employee may use a combination of those options, such as; (i) leave the funds in the former employer’s plan, if permitted, (ii) roll over the funds to a 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 individual’s age, result in adverse tax consequences). If we recommend that a client rollover a retirement plan assets into an account to be managed by our firm, such recommendation creates a conflict of interest insofar as we will earn an advisory fee on the rolled over assets. Clients are under no obligation to roll over retirement plan assets to an account managed by us.