TSA Portfolio Management Inc. (“TSA”), founded in 1991, provides investment supervisory services through investment management programs by giving continuous advice to you and by making investment decisions and recommendations based on individual client’s needs. Through personal discussions, TSA develops a personal investment policy, and creates and manages a portfolio based on your goals and objectives derived from information provided by each client. . Your portfolio may include investments in load or no-load mutual funds, stock, individual bonds (corporate, government and municipal), variable annuities and exchange traded funds (ETFs). TSA manages advisory accounts on a discretionary and non-discretionary basis. Account supervision is guided by your stated objectives and risk tolerance level (i.e., maximum capital appreciation, growth, income, or growth and income). _________________________________________________________________________________________________________ Principal Owners TSA is a division of Halliday Financial Group, Inc. which (as of January 2016) is owned by the following individuals: Rachel Holste Halliday Pino, CCO, Denis J. Moynihan, II, President and Portfolio Manager and Sean Mohammadi, Owner. ______________________________________________________________________________________________________ Types of Agreements Individual Customized Portfolios The following types of agreements define the typical relationship:
• Discretionary: A discretionary contract allows TSA to execute trades for your account at our discretion without requiring prior client approval for each specific investment. If you so choose, we will accept discretionary authority to manage securities accounts on your behalf. This will give TSA the authority to determine, without obtaining specific consent, the particular securities to be bought or sold; the amount of the securities to be bought or sold; and the timing as to when to make transactions for the account.
• Non-Discretionary: Non-discretionary accounts require TSA to obtain your authorization prior to executing each transaction. We will provide the client with our recommendations, which must be accepted by the client prior to implementation. INDIVIDUAL PORTFOLIO MANAGEMENT TSA Portfolio Management through our various programs offer investment strategies for specific clients based upon the Client’s investment objectives, financial status, risk tolerance and specific instructions provided by the Client. Each Client has the ability to impose reasonable restrictions on the management of his/her funds. For example, the client can designate particular equities, bonds, exchange-traded funds (“ETF’s”) and mutual funds or types of equities, bonds, ETF’s and mutual funds that should not be selected for his/her account. Any restrictions imposed will be designated on each client’s Portfolio Selection Form. TSA Portfolio Management uses a variety of sources to implement investment strategies. Special attention is given to the tax consequences of investments in taxable accounts to address the Client’s tax situation. Relatively aggressive investment strategies that may be adopted under certain and rare circumstances are transactions utilizing margin borrowing and option-writing (including uncovered options or spreading strategies). These strategies require special consideration and written approval from the Client before being utilized. A Portfolio Selection Form is utilized to prepare a model portfolio that our clients select to determine the manner in which they want their account invested. Each model portfolio is designed to meet a particular investment goal. The model portfolio types are listed below with a description of each TSA Portfolio Managed Funds (“STAR”), North Shore Funds (“NSF”), American Funds (“AMF”), City University Options (“CUNY”) : STAR-Equity 20 – 5% of the portfolio is invested in each the S&P 500, Large Value, Small Cap and International Equity Markets. Corporate and Government bonds are 78% of the portfolio with 2% in a money market. STAR-Equity 40 – 10% invested in each the S&P 500, Large Value, Small Cap and International Equity Markets. The 1-year Corporates are at 28%- and 5-year Government is 30% with 2% in the money market. STAR-Equity 60 – 15% invested in each the S&P 500, Large Value, Small Cap, 10% International Equity Markets. Bonds 45%. STAR-Equity 70 – 15% invested in each the S&P 500, Large Value, Small Cap and International Equity Markets. 1 Year Corporates are 18%- and 5-Year Government is 20% with 2% in the money market. STAR-Equity 80 – 20% invested in each the S&P 500, Large Value, Small Cap and International Equity Markets. 1 Year Corporates are at 8%- and 5-Year Government is 10% with 2% in the money market. STAR-Option 100 – 20% in each the S&P 500, Large Value and International Equity Markets. Small Cap Value and Small Cap Growth are 10% and Mid Cap Value and Mid Cap Growth are at 9% with 2% in the money market. STAR-Option 100 Retirement – 12% invested in each the S&P 500, Small Cap, Mid Cap and International Equity Markets. Large Value is 50% with 2% in the money market. NSF-Equity Weighted 50 –50% of the portfolio is invested in large cap and middle cap dividend paying companies with a small tactical percentage in equity exchange traded funds (ETFs). 48% is invested in medium- and short-term bond ETFs with the balance in a firm approved money fund. NSF-Equity Weighted 70 – 70% of the portfolio is invested in large cap and middle cap dividend paying companies with a small tactical percentage in equity exchange traded funds (ETFs). 28% is invested in medium-and short-term bond ETFs with the balance in a firm approved money fund. NSF-Equity 100 – 98% of the portfolio is invested in large cap and middle cap dividend paying companies with a small tactical percentage in equity exchange traded funds (ETFs). There is a varying allocation to a firm approved money fund. NSF -Equity 50 – 50% of the portfolio is invested in combination of large cap and middle cap dividend paying companies and equity exchange traded funds (ETFs). Within this 50% equity allocation, 60% is comprised of the individual equities while 40% is allocated across large cap, midcap, small cap and international ETFs. The 50% bond allocation is invested in medium- and short-term ETFs (48%) with the balance in a firm approved money fund. NSF -Equity 60 –60% of the portfolio is invested in combination of large cap and middle cap dividend paying companies and equity exchange traded funds (ETFs). Within this 60% equity allocation, 60% is comprised of the individual equities while 40% is allocated across large cap, midcap, small cap and international ETFs. The 48% bond allocation is invested in medium- and short-term ETFs (40%) with the balance in a firm approved money fund. NSF -Equity 70 – 70% of the portfolio is invested in combination of large cap and middle cap dividend paying companies and equity exchange traded funds (ETFs). Within this 70% equity allocation, 60% is comprised of the individual equities while 40% is allocated across large cap, midcap, small cap and international ETFs. The 30% bond allocation is invested in medium- and short-term ETFs (28%) with the balance in a firm approved money fund. NSF -Equity 80– 80% of the portfolio is invested in combination of large cap and middle cap dividend paying companies and equity exchange traded funds (ETFs). Within this 80% equity allocation, 60% is comprised of the individual equities while 40% is allocated across large cap, midcap, small cap and international ETFs. The 20% bond allocation is invested in medium- and short-term ETFs (18%) with the balance in a firm approved money fund. NSF -Equity 100-100% of the portfolio is invested in combination of large cap and middle cap dividend paying companies and equity exchange traded funds (ETFs). Within this equity allocation, 59% is comprised of the individual equities while 39% is allocated across large cap, midcap, small cap and international ETFs. The balance is invested in a firm approved money fund. AMF-Equity Weighted 20 – 11.3% of the portfolio is invested in U.S. stocks. 7.9% is invested in non-U.S. stocks. A balance exist between growth and value for all stock positions. 66.5% is invested in U.S. bonds and 10.2% in non-U.S. bonds. And the cash position varies but averages around 4.3%. AMF-Equity Weighted 40 – 20.9% of the portfolio is invested in U.S. stocks. 17.3% is invested in non-U.S. stocks. A balance exist between growth and value for all stock positions. 49.9% is invested in U.S. bonds and 7.6% in non-U.S. bonds. And the cash position varies but averages around 4.3%. AMF-Equity 70 – 48.5% of the portfolio is invested in U.S. stocks. 16.5% is invested in non-U.S. stocks. A balance exist between growth and value for all stock positions. 27.6% is invested in U.S. bonds and 2.6% in non-U.S. bonds. And the cash position varies but averages around 4.8%. AMF-Equity 80 – 53.2% of the portfolio is invested in U.S. stocks. 21.4% is invested in non-U.S. stocks. A balance exist between growth and value for all stock positions. 18.6% is invested in U.S. bonds and 2.6% in non-U.S. bonds. And the cash position varies but averages around 4.3%. AMF-Equity 100 – 66.3% of the portfolio is invested in U.S. stocks. 28.5% is invested in non-U.S. stocks. A balance exist between growth and value for all stock positions. And the cash position varies but averages around 5.2%. AMF-Equity 100 Retirement – 66.3% of the portfolio is invested in U.S. stocks. 28.5% is invested in non-U.S. stocks. There is a significantly weighting to “value” and dividend producing stocks. And the cash position varies but averages around 5.2%. AMF-Equity 70 Retirement– 48.5% of the portfolio is invested in U.S. stocks. 16.5% is invested in non-U.S. stocks. There is a significantly weighting to “value” and dividend producing stocks. 27.6% is invested in U.S. bonds and 2.6% in non-U.S. bonds. And the cash position varies but averages around 4.8%. AMF-Equity 80 Retirement– 53.2% of the portfolio is invested in U.S. stocks. 21.4% is invested in non-U.S. stocks. There is a significantly weighting to “value” and dividend producing stocks. 18.6% is invested in U.S. bonds and 2.6% in non-U.S. bonds. And the cash position varies but averages around 4.3%. CUNY Aggressive Portfolio: an investment strategy emphasizes capital appreciation as a primary investment objective, rather than income with greater volatility. CUNY Growth Portfolio: aims to increase the value of your savings. It generally favors stocks, which – though potentially volatile – have historically delivered higher returns than other asset classes such as bonds. CUNY Growth and Income Portfolio: seeks to help investors build assets over time through exposure to a wide variety of stock investments as well as income from dividend-paying companies and fixed-income securities. CUNY Conservative Portfolio: seeks to help investors that want current income and less volatility and therefore a lower allocation to stock investments. These investors are not concerned about increasing the value of your investments. CUNY Retirement Income Portfolio: as you transition from the "accumulation" stage to the "distribution" stage, this portfolio strategy seeks to provide a stream of payments via a systematic withdrawal plan using several investment asset classes. CUNY Retirement Income & Growth Portfolio: as you transition from the "accumulation" stage to the "distribution" stage, this portfolio strategy seeks to provide a stream of payments via a systematic withdrawal plan using several investment asset classes. The portfolio's focus is income however it does not overlook the potential for growth. The TSA Separately Managed Account program (“SMAs” by NSF ) are discretionary managed investment accounts that provide you with a personalized approach to investing, including direct ownership of individual securities, tax management, with an active investment management approach. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• ETFs
• Securities traded over-the-counter
• Mutual fund shares When selecting stocks to include in portfolios, our managers look for larger, name-brand equities with strong dividend yields. A stock is even more attractive if it has had a history of increasing dividends and is trading at a discount to its market value. In addition, ideally the company would have free cash flow and reserves to support the dividend. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. SUB ADVISORY PROGRAMS TSA also offers advisory management services to our clients through various commonly used sub advisory programs. Our firm provides the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. Based on the client's individual

circumstances and needs, TSA will then perform management searches of various unaffiliated registered investment advisers (sub advisors) to identify which registered investment adviser's portfolio management style is appropriate for that particular client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected registered investment adviser. Clients should refer to the selected registered investment adviser's brochure or other disclosure document for a full description of the services offered. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. Once we determine the most suitable investment adviser(s) for the client, we provide the selected sub advisors with the client's investment criteria. The sub advisor then creates and manages the client's portfolio based on the client's individual needs. We monitor the performance of the selected registered investment adviser(s). If we determine that a particular selected registered investment adviser(s) is not providing sufficient management services to the client or is not managing the client's portfolio in a manner consistent with the client's PIPS, we may suggest that the client contract with a different registered investment adviser. Under this scenario, our firm assists the client in selecting a new registered investment adviser. However, any move to a new registered investment adviser is solely at the discretion of the client. SUB ADVISOR RELATIONSHIPS Below are the descriptions of the various portfolio options currently available under the various platforms which we offer our clients from third party managers. Managed 360 (Formerly Lockwood Managed Account Advisor (“MAA”)) Program MAA is a program sponsored by Lockwood, with clearing and custody services through its affiliate Pershing LLC (“Pershing”), member FINRA NYSE and SIPC. Lockwood Advisors, Inc. is an SEC- registered investment adviser and is owned by The Bank of New York Mellon Corporation. TSA will utilize software and documentation provided by Lockwood to assist the client in selecting an investment style allocation and/or diversified portfolio of investments including investment vehicle(s) and/or managers (“Manager(s)”) appropriate for you initially and on an on-going basis. TSA will collect financial and personal information from you, assist you in establishing investment objectives and strategies, and evaluate the suitability of the products for you. TSA will then assist you in selecting a Manager(s) from the Lockwood research department’s list of Managers with whom Lockwood does business. Lockwood has limited investment discretion to change the selected Manager(s) if your financial circumstances change or economic or market conditions change, to the extent that Lockwood feels that a Manager change is advisable, or, if in Lockwood’s opinion, the Manager(s) selection can no longer meet the client’s investment objectives. The Manager(s) selected are granted investment discretion by you and exercise this authority in the day-to-day portfolio management of your account(s). Lockwood Advisor Flex Portfolios (“AFP”) Wrap Program Lockwood acts as a Portfolio Manager in offering the AdvisorFlex Portfolios™ (“AFP”) which is a flexible mutual fund and ETF wrap account product. Lockwood is both the sponsor of the Program and the Portfolio Manager of the AFP product. As Portfolio Manager, Lockwood makes limited discretionary investment decisions regarding asset allocation and investment selections. Lockwood will implement certain model updates throughout the life of your AFP account, and you will give Lockwood the limited discretion to implement such updates. Model updates may include replacing one investment vehicle with another or changing the asset allocation. All trades are individual to each AFP account and are not aggregated. You will grant limited discretion to TSA to update the investment vehicles in your account throughout the life an account. Lockwood Investment Strategies ("LIS") Program Lockwood Investment Strategies (“LIS”) is a full discretionary, multi-discipline managed account product housed in a single portfolio. Five core models and four alternative models are available. Lockwood, serving as the Portfolio Manager, determines asset allocation and selects both third- party asset managers (“Sub Advisers”) and specific investment vehicles based on its proprietary approach to asset allocation, as well as its macroeconomic outlook and investment discipline. The account is rebalanced periodically to reflect the market changes and to maintain compliance with Lockwood's strategy-specific guidelines and your investment objectives. TSA will provide you with an asset allocation strategy developed by Lockwood through personal discussions in which goals and objectives based on your particular circumstances are established. This asset allocation strategy is drafted into your Personal Investment Policy Statement. You will grant limited discretion to Lockwood to rebalance the account by replacing one investment vehicle or model with another. You will also grant TSA limited discretion for the purpose of making investment vehicle, model, and asset allocation selections. Lockwood has the ability, subject to certain limitations, to override Lockwood’s proposed asset allocation and/or investment proposal. Lockwood Asset Allocation Portfolios ("LAAP") Program Lockwood Asset Allocation Portfolios (“LAAP”) is a discretionary, mutual fund and ETF wrap account product. Lockwood, serving as the Portfolio Manager, determines asset allocation strategy and selects investment vehicles for the portfolios, based on its proprietary approach to asset allocation, macroeconomic outlook and investment discipline. These portfolios may consist of open and closed-end mutual funds, ETFs and other types of securities, as determined by Lockwood, in its sole discretion. The securities currently used in the LAAP portfolios are subject to change at Lockwood’s sole discretion. TSA will provide you with an asset allocation strategy developed by Lockwood through personal discussions in which goals and objectives based on your particular circumstances are established. This asset allocation strategy is drafted into your Personal Investment Policy Statement. You will grant limited discretion to Lockwood to rebalance the account by replacing one investment vehicle or model with another. You will also grant TSA limited discretion for the purpose of making investment vehicle, model, and asset allocation selections. TSA has the ability, subject to certain limitations, to override Lockwood’s proposed asset allocation and/or investment proposal. Marstone TSA provides a sub advisor relationship with Marstone who manages an Online Wrap Fee Program. Marstone provides online financial advisory services through a secured website: ww.marstone.com; which can create investment plans and portfolio management strategies to meet your financial objectives, including identifying: ● Investment objectives and risk tolerance; ● Indexed asset classes in which to invest; ● Efficient investment allocation to meet your objectives; and ● Appropriate times to re-balance your portfolio to optimize return for your stated objectives and risk tolerance. Through the Marstone platform, detailed information provided from you will assist to evaluate your investment objectives, risk tolerance and suitability considerations. Marstone will help you invest in a well-diversified portfolio of ETFs that may include exposure to stock market holdings for long term returns, fixed income securities for steady income, real estate and commodities for diversification and inflation protection, and often cash-equivalent investments such as money market funds. Based on your investment objectives and through the online tools, Marstone will recommend customized solutions to meet your particular needs. Marstone Wrap Fee Program Marstone offers account management services to clients on a discretionary basis. The accounts will be set up and maintained at the TSA custodian, Pershing Advisor Solutions, LLC (“Pershing”). Marstone fees will be based on the market value of a client account’s assets under management determined on the last business day of the previous monthly period and will become due the first day of the new business month. Marstone clients shall receive both investment advisory services and the execution of brokerage transactions for a specified amount ‘wrapped’ into a single fee (the “Program”). Participation in the Program may cost more or less than purchasing such services separately. In addition, the monthly fee for participation in the Program may be higher or lower than that charged by other sponsors of comparable wrap fee programs. The terms and conditions for client participation in the Program are set forth in this Brochure. Additional Investment Portfolios: Illiquid Direct Participation Investments (DPls): The Adviser conducts due diligence on different illiquid direct participation investments (DPls). DPI offering structures may be private equity (for example, Regulation D, Regulation A, etc.), public non- traded offerings (for example, S-1 offerings, Intrastate offerings, Business Development Companies (BDCs), non-traded mutual funds, etc.), non-traded Real Estate Investment Trusts (REITs), and/or non-traded oil and gas programs. DPls will often have minimum investor suitability standards, which are disclosed within an investment's prospectus or offering circular. More restrictive State or firm-level suitability or concentration standards may be applied. For purposes of determining suitability, the Adviser defines the following terms:
• Annual Income- Personal income from sources such as employment, alimony, social security, investment income, etc.
• Household Net Worth - The value of all assets minus all liabilities. Assets include stocks, bonds, mutual funds, other securities, bank accounts, real assets (e.g., real estate), and other personal property as well as primary residence. Liabilities include mortgage, margin loans, outstanding loans, credit card balances, taxes, etc.
• lnvestable Net Worth - The value of "investable" assets minus liabilities associated with those assets. lnvestable assets include stocks, bonds, mutual funds, other securities, bank accounts, hard assets (e.g., real estate), and other investments less any costs associated with liquidating such assets (e.g., redemption fees, contingent sales charges, sales commissions, taxes and tax penalties if the client is less than 59.5 years old and liquidating qualified accounts, etc.) Primary residence, personal-use automobiles, and personal belongings are not included. Liabilities include any margin loans and other associated outstanding loans. Any mortgage on the primary residence is not included unless the mortgage balance is greater than the fair market value of the primary residence. If this should happen, the amount of the mortgage that is greater than the value of the home is included as a liability. Any amount of the mortgage balance that has increased over the prior 60 calendar days of calculating net worth is included.
• Liquid Net Worth - lnvestable New Worth minus assets that cannot be converted quickly and easily into cash, such as real estate, business equity, personal property and automobiles, expected inheritances, assets earmarked for other purposes, and investments or accounts subject to substantial penalties (e.g., penalties or redemption fees greater than five percent of the face value of the investment) if they were sold or if assets were withdrawn from them.
• Accredited Investor - As defined under Rule 501 of Regulation D under the Securities Act, an Accredited Investor is an individual or joint with spouse with greater than $1,000,000 in lnvestable Net Worth, or individual Annual Income in excess of $200,000 in each of the two most recent years, $300,000 if jointly, and has a reasonable expectation of reaching the same income level in the current year.) While DPls may offer interval-based (i.e., quarterly), periodic tender offers, or some other form of an early redemption feature, in general, any DPI should be considered illiquid. That is, an investor an investor should consider any DPi as being illiquid and without a secondary market upon which to sell one's investment and thus no opportunity to convert one's investment into cash. Anticipated holding periods will vary depending on the nature and strategy of the DPI. The Adviser will communicate anticipated holding periods per language provided within each DPl's prospectus or offering circular. However, there is no guarantee that a liquidity event will occur within the prescribed timeframe if at all. All DPls should be considered speculative in nature, subject to a high degree of risk, including the risk of losing one's entire investment. DPls are not endorsed by FINRA, SEC, or any other regulatory agency. TSA Assets Under Management As of 12/31/2023, TSA manages approximately $1,114,258,972.00 in assets for approximately 2500 clients. Approximately $975,053,224.00 is managed on a discretionary basis and $139,205,748 is managed on a non-discretionary basis.