We have been in continuous operation since our incorporation in June 2002. We offer financial advisory services to clients on either their employer sponsored retirement program accounts or their personal investment accounts. We also offer Financial Planning and advice to sponsors of 401(k) and 403(b) plans. StraightLine acts as your Fiduciary, which means we are obligated to always do what is in your best interest. Our compensation is not commission based but is either a flat fee or is calculated as a percentage of assets under management. We are a fee only Adviser. Michael F. Bisaro, President and CEO is our owner, and Doris C. Karras, our Chief Compliance Officer. Additional information about our personnel may be found in our brochure supplement. Services to Individuals Discretionary Investment Management – StraightLine's Flagship Discretionary Investment Management service combines our institutional research and money management capabilities with our knowledge of your personal financial situation to develop a portfolio strategy to maximize your potential to achieve your financial goals. As part of the ongoing management of your assets, your StraightLine team will be responsible for selecting investments held in your portfolio and for processing all transactions in a timely and accurate manner to ensure continuous alignment between your portfolio strategy and financial goals. We will communicate with you via email or U.S. Mail at least quarterly with market information and account updates. Accounts Outside of Employer Sponsored Plan Assets: We manage personal investment accounts such as IRAs, trusts, joint accounts, or individual accounts on a discretionary basis using our discretionary investment management service. We generally recommend using a qualified custodian that we have a relationship with as the account custodian, and we actively manage these accounts on their platform. (See Item 12 Brokerage Services for additional information regarding the qualified custodians we recommend.) When you become a client after an initial consultation, signing an agreement to work together and information gathering, your account(s) will be opened by a qualified custodian. Once the account is funded, we begin our discretionary management program, investing your account in stocks and bonds, or in mutual funds and Exchange Traded Funds (ETFs). In most cases we use mutual funds and ETFs to provide the diversification and market coverage we feel is necessary for you, depending on your risk tolerance and financial circumstances. Fund selection is based on a wide variety of factors that our Research Department studies including cost, performance of the fund itself vs. its peers and the industry as a whole. We also consider factors such as how long the manager has been in charge, style drift (if it is billed as a certain type of fund, we make sure that’s how it is actually invested). We use a variety of tools in this extensive research process, as well as information about the larger economic picture, historic market information, etc. Please see Item 8 for additional information regarding our investment process including the selection and monitoring of your portfolio. Employer Sponsored Retirement Account For individuals who participate in an employer sponsored retirement plan such as a 401(k),403(b), or 457(b), we offer discretionary account management, meaning we determine how to invest your account assets and then we actively manage the account for you. We make strategic reallocation decisions periodically and, using either an advisor login or your internet username and password, implement those changes in your account. We analyze the funds available in your employer’s plan and we select the funds we will recommend to you. If you become our client, we will meet with you in person or by phone to determine your risk tolerance and overall goals for investment of your account. Use of Sub-Advisors: Based on client circumstances, StraightLine can engage with sub-adviser(s) to provide additional fixed income, equity, and alternative investment opportunities if your investment and risk profiles, as well as your total assets (generally $500,000 investable assets), make these choices appropriate. Separate accounts will be created on a qualified custodian’s account platform for these investments. For these strategies, a separate management fee will be paid by you, in addition to StraightLine’s regular management fee. That fee will be similar to the internal fees charged by mutual fund managers. Non-Discretionary - Portfolio Allocation Service Our Portfolio Allocation Service is a non-discretionary investment management service available only for employer sponsored retirement accounts that leverages the firm’s institutional research and money management capabilities to provide you with a portfolio

allocation based on your risk tolerance and time horizon. Your StraightLine team will continue to provide recommendations on the allocation and selection of investments held in your employer sponsored retirement account to ensure ongoing alignment with your portfolio allocation. With this service, all investment decisions remain with you, as well as the responsibility for processing all transactions to ensure your recommended allocation remains aligned with your portfolio. Financial Planning StraightLine provides a collaborative and ongoing goals-based financial planning service focused on retirement readiness. While included in our Discretionary Investment Management Service, additional fees could apply if the planning is more complex or comprehensive in nature. Financial Planning can also be a standalone service. Cash Management Service StraightLine provides a discretionary cash management service for emergency reserves or assets earmarked for specific short to intermediate-term goals where the client’s primary objective is capital preservation while seeking to maximize return. This service is for assets separate and distinct from our Discretionary Asset Management service, which is designed to manage assets earmarked for achieving longer-term financial goals. Cash Management services may include the use of cash, money market funds, certificates of deposit, short-term bonds (maturity 7 years or less), and ETFs. Employer Services Services to Employer Retirement Plan Sponsors StraightLine’s Employer Retirement Plan Services delivers general education, communication, and advice to employees in employer-sponsored retirement plans. By focusing on the individual employees, StraightLine is helping the plan sponsor achieve their primary goal of maximizing retirement readiness for all employees. There are two components to this service: Education and Communication StraightLine will partner with you to build an education and communication plan that works best for your plan. This includes determining content, methods of communication, and frequency of such communications. Activities would include:
• In-Person Group Meetings that can be focused on financial education topics, current market events, plan features, or plan changes that need to be communicated.
• In-person One-On-One Meetings with employees where education becomes personal. Here we can review individual goals and retirement accounts.
• “Lunch & Learn” Webinars – designed to provide ongoing financial education on timely topics that help build financial awareness to improve the overall financial wellness of your employees.
• Ongoing Access – Throughout the year, your employees will always have access to a StraightLine representative to answer any general questions they may have.
• “StraightTalk from StraightLine” – Regular newsletter and other periodic communications designed to keep employees informed and supplement our education efforts. Separately Offered Advice to Individuals Employees will have access to our Discretionary Investment Management service or our Portfolio Allocation Service for a separate fee. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title 1 of the Employee Retirement Income Act (ERISA) and the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. 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 yours 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 your best interest;
• Charge no more than a level fee that is reasonable for our services; and
• Give you basic information about conflicts of interest. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs and certain other administrative fees. StraightLine does not participate in wrap fee programs. Assets Under Management We manage assets on both a discretionary and non-discretionary basis. As of December 31, 2023, we had $1,068,860,753 in client assets managed on a discretionary basis and $52,333,500 in client assets managed on a non-discretionary basis. Total Assets Under Management of $1,121,194,253.