Description of the Advisory Firm Guidance Point Advisors, LLC ("GPA") has been in business since October 2008. Wesley Austin Del Col, is the firm's managing partner and majority owner. Robert Egidio Del Col is a Preferred A unit holder. Robert Egidio Del Col is not involved in the activities of GPA. Andrew J. Walker and Benjamin J. Smith, investment adviser representatives of GPA, are Preferred B unit holders.
Types of Advisory Services GPA provides fee-based investment supervisory services, financial planning services and retirement income planning services to advisory clients.
Investment Supervisory Services Asset Management by Guidance Point Advisors GPA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GPA provides custom asset management to meet the client's objectives. These services are generally provided on a discretionary basis; however, clients may elect to have services delivered on a non-discretionary basis. Our investment philosophy is premised on diversification and asset allocation. While macroeconomic conditions, market conditions, and other quantitative measures might cause GPA to tactically shift a portfolio away from its target allocation, GPA ultimately seeks to manage the portfolios, over the long term, to each client's appropriate target allocation. GPA utilizes an investor profiling questionnaire which takes into account each client's current situation (income, time horizon, and risk tolerance levels). Based on the information collected, a Statement of Investment Selection (the Investment Policy Statement) is created for each client, to aid in the selection of a portfolio that matches each client's specific situation.
Our Investment Supervisory Services include, but are not limited to, the following:
•Investment strategy •Personal investment policy
•Asset allocation •Asset selection
•Risk tolerance •Regular portfolio monitoring GPA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Investor risk ratings are documented in the Investment Policy Statement, which requires signature by each client. Turnkey Asset Management Programs (TAMPs) GPA does not participate in wrap fee programs, as the fees charged in the asset management programs offered through GPA do not include fees for brokerage, execution and custody; however, it does offer asset management programs through Envestnet Portfolio Solutions ("Envestnet"). In these programs, Envestnet provides various administrative and investment management services to GPA clients. Client assets may be managed on a discretionary basis by GPA through one or more of Envestnet's Advisor-Directed programs, or may be managed by GPA on a non-discretionary basis through one or more of Envestnet's Model-Driven programs. Adviser-Directed assets are managed using a similar process that GPA applies to client assets managed outside of the Envestnet program 4 (see "Asset Management by Guidance Point Advisors" above). Clients who participate in a model- driven program are placed in model allocations managed by Envestnet (Model-Driven) and grant Envestnet full discretionary authority over the assets placed in the program. GPA receives a portion of the total management fee charged to clients invested through Envestnet, regardless of whether client assets are managed in the adviser-directed or model-driven programs. GPA and Envestnet are compensated for their services via a fee share arrangement. Additional information about the fees charged to a client participating in one of the Envestnet programs may be found under Item 5 in this brochure.
As part of our portfolio management services, GPA also provides access to sub-advisory services offered through Vanguard Personalized Indexing Management ("VPI") to manage a portion or all of your account on a discretionary basis. In this arrangement, VPI is a provider of separate account management services/sub-advisory services. GPA coordinates with VPI to develop a portfolio based upon a client's goals and objectives. GPA will work with VPI in selecting an appropriate model portfolio to manage your account. We will regularly monitor the performance of your accounts managed by VPI, and may hire and fire VPI without your prior approval. GPA's investment management fee is separate and distinct from the fees charged by VPI for this service. Additional information about the fees charged to a client participating in the Vanguard Personalized Indexing Management program may be found under Item 5 in this brochure. Additional information about the Vanguard Personalized Indexing Management is available in the VIP Disclosure Brochure which will be provided to clients and is also available upon request. Additionally, the performance reporting provided

by VPI to participants in this program will only show performance "net of fees" of the VPI service fee. The VPI "net of fees" performance reporting is not inclusive of GPA's investment management fee.
Financial Planning Services Financial plans and financial planning may include recommendations for portfolio customization and may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These services are provided to Asset Management clients at no additional cost, but may be contracted for separately for a fixed or hourly fee, which will be documented in the Financial Planning Agreement.
Newsletter GPA provides a quarterly newsletter, free of charge, to its clients and prospects offering general investment advice and other relevant information.
Services Are Not Limited to Specific Types of Investments GPA does not specialize in any particular type of advisory service or provide investment advice only with respect to limited types of investments. Advice may be provided on, but is not limited to, the following types of investments: exchange listed securities, over-the-counter securities, foreign securities, warrants, options, corporate debt securities, CDs, municipal securities, mutual funds, ETFs, third party money managers, REITs, and United States government securities.
5 GPA may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, over valuation or overweighting of the position(s) in the portfolio, change in risk tolerance of client, or any risk deemed unacceptable for the client's risk tolerance. GPA may use other securities as well to help diversify a portfolio when applicable.
Client Tailored Services and Client Imposed Restrictions GPA's services consider each client's financial needs and objectives individually, which may include retirement planning goals, college planning needs, insurance and investment planning, maintaining adequate cash reserves, or other client-specific objectives. GPA provides comprehensive guidance related to the management of a client's assets and income with these needs and objectives in mind. GPA will attempt to provide accurate and comprehensive advice and recommendations to assist clients in meeting these goals.
Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent GPA from properly servicing the client account, or if the restrictions would require GPA to deviate from its standard suite of services, GPA reserves the right to end the relationship.
If a client engages GPA for financial planning services, GPA will tailor such services to the specific needs of the financial planning client, based on the client's current situation (income, tax levels, and risk tolerance levels). IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or 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 is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
6 Amounts Under Management As of January 18, 2023, GPA had $341,906,883 in discretionary assets under management.