A. Cross Staff Investments, Inc., doing business as Candace Shira Associates, LLC (“the Firm” or “CSI”) is a registered investment advisor based in Pittsford, NY. The Firm is incorporated under the laws of the State of New York. The Firm has been incorporated since December 2012. Before Cross Staff Investments, Inc., the advisors were Investment Advisor Representatives providing advisory services under other registered investment advisors. The Firm is considered fiduciaries due to the type of services we provide. The principal owner of the Firm is Candace Shira, sole owner and President. B. The Firm offers the following services personalized to each individual Client: a. Financial Planning b. Investment Management c. Use of Third Party-Money Management Our Financial Planning service involves general recommendations as to asset allocation or security selection of either a selected account, or across a Client’s entire financial portfolio. The Client determines what accounts and/or assets we will review and provide advice on. Some of the areas that we may focus on are cash flow, retirement goals, asset allocation, estate goals, or education analysis, as well as budgeting reviews. The Firm may provide periodic investment review for accounts held outside of the Firm’s affiliation (i.e., 401K, 403B, etc.) if requested by the Client. For these types of reviews, the Clients will be expected to provide a copy of their most recent statements, as well as the investment choices for the account, if applicable. The Client will then be responsible for acting on any changes they see fit. The Client may choose to give the Firm authority to discuss their financial matters with attorneys, tax preparers, their bank, health care professionals, etc. to allow the Firm to better assist the Client in their financial planning. Such authority will be given in writing and/or documented in the Client’s file maintained with the Firm. The Firm may also be given discretionary authority

for only those accounts held at the custodians the Firm works with by agreement. This allows the Firm to conduct trades deciding on security, amount, and whether to buy or sell, if necessary. Investment Management securities are limited to publicly traded stocks, mutual funds and exchange traded funds as well as bonds and certificates of deposit and other cash equivalent holdings. Clients may hold all or only a portion of the securities listed here. The Firm may also utilize Third-Party Money Managers to provide investment management services, which may include other investments than those listed here. The advisor and/or Client will determine which type of securities will be utilized for management. The Firm and Client may decide to utilize a Third-Party Money Manager to assist in making trading decisions in a Client’s account. Currently the Firm utilizes Advisor’s Asset Management and SEI. The Firm also has access to Schwab’s Managed Platform which has additional Third-Party Money Managers the Clients can choose from. The Firm will conduct due diligence on all Third-Party Money Managers prior to introducing them to a Client. All Third-Party Money Managers will provide their individual ADV Part 2a (and 2b if necessary) which will provide more in-depth information regarding the Third-Party Manager and their investment style, fees, risks of investing, etc. C. The Firm tailors our advisory services to the individual needs of the Clients. The Client may at times impose investment restrictions on certain securities or types of securities. Those investment restrictions will be monitored by the Advisor as well as by the Firm. If investment restrictions are in place, it may affect the overall performance of the Clients’ accounts. D. Cross Staff Investments does not participate in a wrap fee program. E. Cross Staff Investments manages $360,451,696 of assets on a discretionary basis and $6,991,440 of assets on a non-discretionary basis as of December 31, 2023.