Cooper/Haims Advisors, LLC (“Cooper/Haims” or “the Firm” or “we”) is an investment adviser registered with the SEC since November 2002 and is a Limited Liability Company formed under the laws of the State of New York. Cooper/Haims was acquired by ESL Investment Services, LLC, a FINRA member broker-dealer on October 1, 2019. ESL Investment Services, LLC is wholly-owned by ESL Federal Credit Union. General Description of Primary Advisory Services As an SEC registered investment adviser, Cooper/Haims offers investment advisory services to retail investors for an ongoing asset-based fee based on the value of cash and investments in your account. Our advisory services include financial planning, tax planning and preparation, and asset management. The following are brief descriptions of Cooper/Haims’ primary advisory services. A more detailed description of Cooper/Haims’ services is provided in Item 5 – Fees and Compensation so that clients and prospective clients can review the description of services and the description of fees side-by-side. Financial Planning Services - Financial planning services do not involve the active management of client accounts, but instead focus on a client’s overall financial situation. The role of a financial planner is to find ways to help the client understand their overall financial situation and increase the client’s potential to meet their financial objectives. At the outset of each engagement, you will be required to sign an Advisory Agreement which describes Cooper/Haims’ services and the general terms for the engagement. Financial planning can be described as helping individuals determine and set their long-term financial goals, and increase their potential to meet them, through investments, tax planning, estate planning, asset allocation, risk management, retirement planning, cash flow analysis, and other areas. Services involve a detailed review of each client’s personal and financial goals, and the development of a comprehensive plan that addresses issues that are relevant to your situation. These services generally include the collection of relevant data, the development of a net worth statement, a determination of cash flows, annual expense and annual savings projections, and a projection of asset growth over a specified period. Depending upon your situation, financial planning services may also include the following: Analysis of Employee Benefits
• Collection of relevant data;
• Review of retirement plan formula;
• Review of tax-deferred savings plans;
• Review of insurance coverages; and
• Review of equity compensation including stock options. Retirement/Financial Independence Planning
• Collection of relevant data;
• Projection of income, expenses, and assets, before and after retirement; and
• Advice concerning employer-sponsored retirement benefits. Cooper/Haims Advisors, LLC 5 Disclosure Brochure Insurance Planning
• Collection of data relating to life, long-term care and disability policies including, as applicable, beneficiary designations;
• Analysis of survivorship benefits;
• Analysis of long-term care benefits;
• Analysis of disability benefits; and
• Gathering of proposals for additional insurance needs as appropriate. Estate Planning
• Collection of relevant data;
• Review of wills, trusts and beneficiary designations for purposes of understanding existing estate plan;
• Analysis of an existing estate plan;
• Discussion of alternative strategies for modifications to existing estate plan; and
• Discussion with an estate attorney regarding recommendations for modifications. Education Planning
• Collection of relevant data;
• Facilitation of a process for creation of a family philosophy for education funding;
• Review of target dates, educational costs, and funding vehicles for children and/or grandchildren; and
• Calculation of needs and resources. Income Tax Planning
• Collection of relevant data;
• Preparation of income tax projections; and
• Analysis and discussion of tax saving opportunities. Income Tax Preparation
• Collection of relevant data;
• Preparation (and submission) of federal and state income tax forms. Asset Management Services - Cooper/Haims provides asset management services that involve implementing one or more investment strategies designed to address each client’s needs. You may grant authority to Cooper/Haims on a discretionary or non-discretionary basis, with specific limitations or restrictions. Discretionary authority is limited by your investment objectives and the guidelines set forth in your Investment Policy Statement (“IPS”). Cooper/Haims’ asset management process is designed to respond to your individual needs and the dynamics of the capital markets. Cooper/Haims gathers data to define your risk profile and investment objectives, then determines an asset allocation that it believes will be suitable for your investment needs. Third-Party Money Managers - Cooper/Haims may refer clients to or select, unaffiliated money managers to manage some or all of the client’s assets. Third-party money managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. Cooper/Haims is responsible for conducting due diligence

of third-party money managers that are selected or referred. Cooper/Haims Advisors, LLC 6 Disclosure Brochure In addition, Cooper/Haims may choose to use specialist managers or Separate Account Programs. Under a Separate Account Program, your assets will be invested in (1) a portfolio of mutual funds (“Mutual Fund Portfolio”), (2) one or more portfolios of individual securities (each a “Managed Account Portfolio”) or (3) a combination of the aforementioned. Each Separate Account Program is managed by a third-party investment manager in accordance with investment strategies selected or recommended by Cooper/Haims. In each instance, the arrangement is governed by an agreement between the client, Cooper/Haims and the third-party manager who is authorized to manage the portfolio assets. You will be responsible for the management fees charged by each Separate Account Program, which is in addition to Cooper/Haims’ fees. You will appoint a custodian for the account who may be affiliated with the third-party investment manager. You will be responsible for the custodian’s fees, if any. Unless the Separate Account Agreement provides otherwise, you will not be responsible for the costs and charges associated with securities transactions, dealer mark-ups, mark-downs, and broker commissions. The custodian will provide to you regular reporting services, including consolidated monthly account statements, quarterly performance reports and annual tax reports. Limits Advice to Certain Types of Investments Cooper/Haims provides investment advice on the following types of investments:
• Mutual Funds
• Exchange-listed securities (i.e., stocks)
• Securities traded over-the-counter (i.e., stocks)
• Fixed income securities (i.e., bonds)
• Closed-End Funds and Exchange Traded Funds (ETFs)
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• United States government securities Cooper/Haims constructs each client’s account to build diversified portfolios, which may include mutual funds, ETFs, bonds, and equities. Cooper/Haims may increase or decrease cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. The Firm may modify its investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Cooper/Haims’ services are provided based on each client’s individual needs. For example, you can impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client one-on-one through interviews and questionnaires to determine their investment objectives and suitability information. Cooper/Haims Advisors, LLC 7 Disclosure Brochure Assets Under Management (“AUM”) by Cooper/Haims As of December 31, 2023, Cooper/Haims had regulatory assets under management of $852,596,325 managed on a discretionary basis, which is reported on our ADV Part 1. In addition to our reported regulatory AUM, we have $175,835,588 of assets under advisement as of December 31, 2023. Miscellaneous Disclosures Individual Retirement Account (“IRA”) Rollover Considerations 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 IRA (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If a client is a participant in an employer-sponsored retirement plan such as a 401(k) plan and decides to roll assets out of the plan into the account, Cooper/Haims would have a financial incentive to recommend that the client invest those assets in the account, because Cooper/Haims will be paid on those assets through advisory fees. You should be aware that such fees likely will be higher than those a participant pays through a plan, and there can be maintenance and other miscellaneous fees. As securities held in a retirement plan are generally not transferred to the account, commissions and sales charges may be charged when liquidating such securities prior to the transfer, in addition to commissions and sales charges previously paid on transactions in the plan. When acting in such capacity, we serve as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by Cooper/Haims. Client Obligations Cooper/Haims is not required to verify any information received from you or your other professionals and will rely on the information in its possession. Clients are responsible for promptly notifying Cooper/Haims if there is ever any change in their financial situation or investment objectives so that it can review, and if necessary, revise its previous recommendations or services.