High Falls Advisors, Inc., (“HFA” throughout this brochure) is a New York State corporation and is registered with the United States Securities and Exchange Commission (SEC) as an investment advisor under the Investment Advisors Act of 1940. The firm’s office is in Rochester, New York. The firm is owned equally by Kenneth Burke, the firm’s President and CEO, and Jennifer Vogler, the firm’s Executive Vice President and Chief Compliance Office. Background: High Falls Advisors, LLC was formed in 2008 as a successor to James H. McBride, R.I.A. (Formed in 1986). On December 31, 2012, James McBride and James Englert changed the corporate structure from an LLC to a corporation. James McBride retired as President and CEO as of December 31, 2016. James Englert was the owner, President and CEO of the firm from January 1, 2017, through January 1, 2020, when ownership was transferred to Kenneth Burke and Jennifer Vogler. Assets under management--As of December 31, 2023, HFA assets under management were: $ 520,584,654.00 which is broken down as follows: U.S. Dollar Amount Discretionary Accounts: $ 520,584,654.00 HFA offers the following services:  Portfolio Management—HFA provides ongoing management of client investment portfolios. The portfolios are managed on a discretionary basis based on the investment objectives and risk profile/tolerance of the client. The portfolios may include investments such as individual securities, mutual funds, Exchange Traded Funds (ETFs), index funds, municipal securities, and government securities. o Core Market Index Portfolio (CMIP)—The portfolios in this strategy are comprised primarily of Exchange Traded Funds (“ETFs”) and some mutual funds, many of which are in the BlackRock family of funds. Our Investment Committee designs the portfolios using BlackRock models. The allocation of funds is based on the investment objectives and risk profile/tolerance of the client. This portfolio is actively managed with a focus on risk mitigation. Portfolios are rebalanced at least quarterly. o Core Market Index Portfolio Tax Aware (CMIP TA) -- The portfolios in this strategy are comprised primarily of Exchange Traded Funds (“ETFs”) and some SEC File # 801-34161 Page 5 mutual funds, many of which are in the BlackRock family of funds. Our Investment Committee designs the portfolios using BlackRock models. The allocation of funds is based on the investment objectives and risk profile/tolerance of the client. This portfolio is actively managed with a focus on tax efficiency and risk mitigation. Portfolios are rebalanced at least annually, but less frequently than quarterly, to achieve tax efficiency. o Core Market Index Portfolio Tax Aware (CMIP ESG) -- The portfolios in this strategy are comprised primarily of Exchange Traded Funds (“ETFs”) and some mutual funds, many of which are in the BlackRock family of funds. Our Investment Committee designs the portfolios using BlackRock models. The allocation of funds is based on the investment objectives and risk profile/tolerance of the client. This portfolio is actively managed with a focus on funds that offer exposure to companies that exhibit favorable environmental, social and governance (“ESG”) practices. Portfolios are rebalanced at least quarterly. o Enhanced Allocation Strategy (EAS)—The portfolios in this strategy are comprised of actively managed mutual funds primarily from the American Fund family of funds. Specific portfolios are selected using an objectives-based process with investor goals and risk profile determining the proper objective. The portfolios are rebalanced when required. o Fidelity Target Allocation Portfolios—The portfolios in this strategy are comprised of either all Fidelity mutual funds or a blended model of Fidelity mutual funds and ETFs from Blackrock, SPDR and other fund companies. Specific portfolios are selected using an objectives-based process with investor goals and risk profile determining the proper objective. The portfolios are designed to provide enhanced risk-adjusted total return.

Portfolios are actively managed and are typically rebalanced two to four times a year. o Personal Asset Management Accounts—The portfolios in this service are custom-designed with emphasis on individual securities. The portfolio selection is based on the investment objectives and risk profile/tolerance of the client and is designed for long-term investing. o Retirement Income Management Strategy—The retirement income portfolios use a combination of portfolios to achieve reduced volatility for client’s near-term retirement spending needs. The strategy uses multi-asset income portfolios for cash-flow in combination with our other investment strategies for the longer-term cash needs. The target allocation of assets in each portfolio is dependent on the client’s immediate retirement income needs. SEC File # 801-34161 Page 6 o 55ip—For certain accounts in the CMIP and Fidelity strategies, HFA leverages the technology of 55 Institutional Partners, LLC (“55ip”), an investment advisor not affiliated with High Falls Advisors, Inc., to serve as a sub-advisor on the accounts. 55ip is granted limited discretionary trade execution authority over the accounts. 55ip will implement trading and rebalancing of client assets through its proprietary online platform, as directed by HFA. 55ip also provides trading for tax-loss harvesting for certain non-retirement client accounts. o Pontera Solutions, Inc.—In cases where a client chooses to have High Falls advise on assets that are not held at our custodian, High Falls is able to provide investment management services of those accounts through a third-party order management system, Pontera Solutions, Inc. (“Pontera”). The accounts that are included are: 401(k) accounts, 403(b) accounts, 529 plans and other similar accounts. Clients give HFA permission via a link through Pontera for HFA to make asset allocation changes via the Client’s online login credentials, which are never made available to, held or stored by HFA. Access provided to HFA is restricted to making changes to the allocation of funds or other securities in the account. HFA is not authorized, at any time, to adjust, add to or subtract from the investment options, to change or access any other plan polices or fees assessed by the plan or the fund providers, to access the financial assets in the account, to make deposits, withdrawals or distributions, or make any changes or additions to beneficiaries or other account profile information. The assets are included in calculating the total assets under management when assessing the advisory fees. Advisory fees for these accounts are either billed directly to the client or, if agreed by HFA and Client, are withdrawn from the client’s brokerage account held with our custodian. o Financial planning services—Through meetings in which goals and objectives are established, HFA provides a customized financial plan for clients. This may be in addition to managing their investment portfolio. Working with the client, we provide guidance on establishing clearly defined objectives and specific strategies for achieving these goals. Such analysis may include current investments, debts, future retirement income, Social Security, pension and retirement income strategies, risk management and insurance coverage, estate planning, tax planning, and cash flow management. It may also include life transition events, such as marriage, divorce, death, eldercare planning, inheritance planning, launching a new business, or selling a business. HFA will tailor the plan to the client’s individual needs. SEC File # 801-34161 Page 7 o Business Planning—HFA may provide additional business consulting services for the small business owners we advise. Services may include advice on business planning, business successions and mergers, insurance needs, tax planning, and coordination of services with attorneys and outside accountants, when applicable. o Tax Preparation—HFA provides individual tax preparation and tax planning as an optional service to its clients.