BIA is a personal wealth management firm dedicated to providing financial and investment advice to its clients. BIA believes in a traditional value approach to asset management that begins with a comprehensive investment plan aimed at determining the client’s current financial position and developing goals that BIA seeks to help each client achieve. Prior to engaging BIA to provide investment advisory services, the client is required to enter into one or more written agreements with BIA setting forth the terms and conditions under which BIA renders its services (collectively the “Agreement”). BIA has been in business since November 2007. Patrick J. Barry is the principal owner of BIA. As of December 31, 2023, BIA had $654,891,161 in assets under management, of which $522,680,795 was managed on a discretionary basis and $132,210,366 on a non-discretionary basis. This disclosure brochure describes the business of BIA. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of BIA’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 BIA’s behalf and is subject to BIA’s supervision or control. Wealth Management Services BIA provides its clients with wealth management services which may include a broad range of comprehensive financial planning services as well as non-discretionary and/or discretionary management of investment portfolios. BIA provides services through the Barry Investment Advisors, LLC Program (the “Wrap Program”), a wrap fee program. Pursuant to the Wrap Program, BIA provides its wealth management services and arranges for brokerage transactions under a single annualized fee. Participants in the Wrap Program may pay a higher aggregate fee than if investment management and brokerage services are purchased separately. A complete description of the Wrap Program’s terms and conditions (including fees) are contained in the Wrap Program’s wrap fee brochure. As described in detail in Item 8 below, BIA primarily allocates clients’ investment management assets among individual equity securities, fixed income, ETFs, and cash equivalents in accordance with the investment objectives of the client. BIA may also recommend mutual funds and closed-end funds for niche investment areas or when appropriate for a particular account size. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by

the Firm unless specifically agreed upon. Clients can engage BIA to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and Page 5 © MarketCounsel 2024 qualified tuition plans (i.e., 529 plans). In these situations, BIA directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. The Firm may utilize a third-party platform that will allow it to make transactions for the client without being deemed to have custody. There will be additional fees for the third-party and can be additional transaction charges. BIA tailors its advisory services to the individual needs of clients. BIA consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. BIA ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify BIA if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon BIA’s management services. Financial Planning and Consulting Services BIA offers clients a broad range of financial planning and consulting services, which include any or all of the following functions. While this can be done as part of a Wealth Management service as described above, it can also be provided as a stand-alone offering. In performing these services, BIA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage BIA or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by BIA under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising BIA’s recommendations and/or services. Page 6 © MarketCounsel 2024