A. The Registrant is a corporation formed on September 9, 2010 in the Commonwealth of Pennsylvania. The Registrant became registered as an Investment Adviser Company in October 2010. The Registrant is owned by Robert Connell and Mr. Connell is also the Registrant’s Principal. B. As discussed below, the Registrant offers to its clients (individuals, business entities, trusts, estates, pension plans and charitable organizations, etc.) investment advisory services, and, to the extent specifically requested by a client, financial planning, and related consulting services. INVESTMENT ADVISORY SERVICES The client can determine to engage the Registrant to provide discretionary and/or non-discretionary investment advisory services on a fee basis. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management. Please see Item 5 for fee structure. Prior to engaging the Registrant to provide investment advisory services, clients are required to enter into a written Investment Advisory Agreement with the Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided and the applicable fees. Registrant may recommend the services of other professionals for implementation purposes, such as attorneys, accountants, and including the Registrant’s representatives in their individual capacities as licensed insurance agents. (See disclosure at Item10 C.8). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent specifically requested by a client, the Registrant may determine to provide financial planning and/or consulting services (including tax planning, investment and non-investment related matters, estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a written Financial Planning, Tax Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes, such as attorneys, accountants, and including the Registrant’s representatives in their individual capacities as licensed insurance agents. (See disclosure at Item10 C.8). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Registrant shall generally provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Registrant will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below for clients who will maintain at least $1 million under the Registrant’s management. Retirement Plan Rollovers – No Obligation / Potential for Conflict of Interest. 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 Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will receive an advisory fee as a result of the rollover. To the extent that Registrant recommends that clients roll over assets from their retirement plan to an IRA managed by Registrant, then Registrant represents that it and its investment adviser representatives are fiduciaries under the Employment Retirement Income Security Act of 1974 (“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 Registrant. Registrant’s Chief Compliance Officer, Joseph R. Weidenburner, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such a rollover recommendation. ADV PART 2A Page 5 of 15 Please Note: Non-Discretionary Service Limitations. Clients that engage Registrant on a non-discretionary investment advisory basis must be willing to accept that Registrant cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Registrant would like to make a transaction for a client's account (including in the event of an individual holding or general market correction), and the client is unavailable, Registrant will be unable to affect the account transaction(s) without first obtaining the client’s consent. Trade away/Prime Broker Fees. Relative to its discretionary investment management services, when beneficial to the client, individual fixed income transactions may be routed through broker-dealers other than the account custodian, in which event, the client generally will incur both the fee (commission, mark-up/mark-down) charged by the executing broker-dealer and a separate “trade away” and/or prime broker fee charged by the account custodian (Fidelity). Fidelity and NuView Trust Company. As discussed below at Item 12, Registrant recommends that Fidelity or NuView Trust Company serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Fidelity charge brokerage commissions and/or transaction fees for effecting securities transactions. In addition to Registrant’s investment management fee, brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Please Note-Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client can obtain many of the mutual funds that may be recommended and/or utilized by Registrant independent of engaging Registrant as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Registrant’s initial and ongoing investment advisory services. Separate Fees: All mutual funds (and exchange traded funds) impose fees at the fund level (e.g. management fees and other fund expenses). All mutual fund fees are separate from, and in addition to, Registrant’s wealth management fee as described at Item 5 below. Registrant’s Chief Compliance Officer, Joseph R. Weidenburner, remains available to address any questions that a client or prospective client may have regarding the above. Client Obligations. In performing our services, Registrant shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should

not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Registrant) will be profitable or equal any specific performance level(s). Non-Investment Consulting/Implementation Services. To the extent requested by the client, Registrant may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, divorce planning, asset valuation, options valuation, retirement plan valuation, qualified plan valuation, deferred compensation plan valuation, insurance, etc. Neither Registrant, nor any of its representatives, serves as an attorney or accountant, and no portion of Registrant’s services should be construed as same. To the extent requested by a client, Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.), including Registrant's principal in his capacity as a licensed insurance agent (see disclosure below). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage the Registrant on a non-discretionary investment advisory basis must be willing to accept that the Registrant cannot affect any account transactions without obtaining prior verbal consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, the Registrant will be unable to affect any account transactions (as it would for its discretionary clients) without first obtaining the client’s verbal consent. AFFILIATED PRIVATE INVESTMENT FUNDS. The Registrant may provide investment advice regarding private investment funds, including those affiliated with Registrant’s Principals. The Registrant, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to the affiliated private funds. The terms and conditions for participation in the affiliated private funds, including management and incentive fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents. Registrant’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Commented [SC1]: Do we need to include American Funds/College America? ADV PART 2A Page 6 of 15 Specifically, the Registrant’s Principals are affiliated with the following private investment funds and/or business ventures (collectively the “affiliated private funds”): AFABJ LLC – a private real estate fund formed for the purpose of investing in a single commercial real estate transaction; initially, a BJ’s Wholesale Club retail location at 131 East Kings Highway in Maple Shade, NJ, which has been transitioned into the Montecito Tower commercial office building in Las Vegas, NV. AFAKOP LLC - a private real estate fund formed for the purpose of investing in a single commercial real estate transaction; the Corsair I Corporate Office building in King of Prussia, PA AFAGV LLC - a private real estate fund formed for the purpose of investing in a single commercial real estate transaction; the Great Valley Commerce Center in Malvern, PA. AFAMAR LLC – a private real estate fund formed for the purpose of investing in a single commercial real estate transaction; the Lippincott Centre office complex at 301 & 303 Lippincott Drive in Marlton, NJ. AFABLU LLC – a private real estate fund formed for the purpose of investing in two commercial real estate transactions; 518 E. Township Line Road, a commercial office complex located in Blue Bell, PA, and 516 E. Township Line Road, a commercial office building in Blue Bell, PA. AFASAU LLC – a private real estate fund formed for the purpose of investing in a single commercial real estate transaction; the Saucon Valley Plaza commercial office building in Center Valley, PA. AFALOC LLC – a private real estate fund formed for the purpose of investing in a single commercial real estate transaction; 4501 New York Ave, a commercial office building in Arlington, TX. AFACOR LLC – a private real estate fund formed for the purpose of investing in a single commercial real estate transaction; 3701 and 3773 Corporate Parkway, two commercial office buildings in Center Valley, PA. Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each qualified client for review and consideration. Unlike other liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please note: Conflict of Interest. Because the Registrant’s Principals and/or their affiliates could earn compensation from the affiliated private funds that exceeds the fee that the Registrant would earn under its standard “assets under management” fee schedule referenced in Item 5.A below, the recommendation that a client become an investor in the affiliated private funds could present a conflict of interest. To mitigate this conflict of interest, the Registrant carefully qualifies eligible clients, and recommends private fund allocations as a means to more broadly diversify client portfolios. No client is under any obligation to become an investor in the affiliated private funds. The Registrant’s Chief Compliance Officer, Joseph R. Weidenburner, remains available to address any questions regarding this conflict of interest. Please note: Valuations. In the event that the Registrant references private investment funds owned by the client on any supplemental account reports prepared by the Registrant, the value(s) for all such private investment funds shall reflect the initial purchase and/or the most recent valuation provided by the fund sponsor. If the valuation reflects the initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. Annual fund audit statements generally contain information related to valuation. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon the information provided. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Disclosure Statement. A copy of the Registrant’s Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning, Tax Planning and Consulting Agreement. Any client who has not received a copy of Registrant’s Brochure at least 48 hours prior to executing the Investment Advisory Agreement or Financial Planning, Tax Planning and Consulting Agreement shall have five business days subsequent to executing the agreement to terminate the Registrant’s services without penalty. Trade Error Policy. Registrant shall reimburse accounts for losses resulting from the Registrant’s trade errors, but shall not credit accounts for such errors resulting in market gains. The gains and losses are reconciled within the Registrant’s custodian firm account and Registrant retains the net gains and losses. ADV PART 2A Page 7 of 15 C. The Registrant shall provide investment advisory services specific to needs of each client. Prior to providing investment advisory services, an investment adviser representative will discuss with each client, their particular investment objective(s). The Registrant shall allocate each client’s investment assets consistent with their designated investment objective(s). Clients may, at any time, impose restrictions, in writing, on the Registrant’s services. D. Not Applicable. E. As of December 31, 2022, the Registrant had $537,914,172 in assets under management on a combined discretionary and non-discretionary basis.