About Quartz Partners Our firm is a limited liability company organized under the laws of the State of New York state. We commenced operations as an SEC registered investment adviser in 2015 pursuant to the Investment Advisers Act of 1940 (the “Act”) and offer fee-based investment advisory services. The firm is wholly owned by Etico Financial, LLC and is operated by Joseph Arena, Chief Investment Officer, Kyle Webber, Chief Operating Officer and Portfolio Manager, and Joseph Leo, Chief Executive Officer. Etico Financial, LLC is owned by Mr. Arena, Mr. Webber, Mr. Leo, and Scott Weisman, Chairman through Pterodactyl Holdings, LLC. Advisory Services Offered We offer advisory services (hereafter “services”) to our clients through two primary business units: “Etico” our private wealth management division through Investment Adviser Representatives (hereafter “Financial Professionals”) affiliated with our firm and “Quartz Partners” our in-house investment mangement division. Our Etico division focuses on providing holistic solutions to our client’s unique financial needs through our affiliated Financial Professional’s acting in the capacity as either an employee or indepdent contractor on behalf of our firm. In contrast, our Quartz Partners division provides various asset-allocation investment strategies to both our clients and non-firm clients through model portfolios, separately managed accounts, and other investment management delivery methods that serve as the building blocks for our clients’ investment portfolios. Collectively, we refer to this herein as our “Strategies”. By combining our Quartz Strategies with third-party managers or our Financial Professionals acting as portfolio manager we seek to optimize our customized portfolio management capabilities for our clients. However, our clients utilizing Quartz investment management services will incur charges in addition to the Financial Professionals advisory fee. As a result, our Financial Professionals have a conflict of interest in recommending our Quartz Strategies. Clients are not obligated to participate in Quartz Strategies. Please Note: This brochure is specific to our Quartz Partners investment management division, to review the brochure specific to our Etico private wealth management division, please visit www.eticofinancial.com or contact us at: [email protected] or 518.348.0060. The following are descriptions of the primary advisory services we offer. Clients are typically introduced to our firm and our advisory services through registered representatives, investment adviser representatives, and solicitors (hereafter “Financial Professionals”) whom our firm has a contractual relationship with. “ Non- discretionary” services require clients to initiate or pre-approve investment transactions in your account managed by our firm (hereafter “Account”) before they can occur, whereas ” discretionary” services authorize the Financial Professional or other designated third-party investment advisor to buy, sell or hold investment positions without obtaining pre-approval from clients for each transaction. Financial Professionals are required by applicable rules and policies to obtain licenses and complete certain training in order to recommend certain investment products and services. You should be aware that your Financial Professional, depending on the licenses and training obtained, may or may not be able to recommend certain investments, models, programs, or services. Please ask your Financial Professional whether any limitations apply. Please understand that a written agreement, which details the exact terms of the Service and advisory fee schedule, must be signed by the client and, in most cases, accepted by our firm before we can provide the client with the Services described below. Our Strategies are used to guide investment decisions in an attempt to dynamically monitor advisory clients’ investments and manage portfolio risk within a client account (hereafter “Account”) on an ongoing and continuous basis. We limit our investment advice and the securities that we utilize in client Accounts to exchange-traded products like exchange traded funds, exchange traded notes (hereafter “ETFs”), pooled investment vehicles defined under the Investment Company Act of 1940, (e.g., Mutual Funds, Variable Annuity Subaccounts) (hereafter “Funds”), equities publicly traded on a major U.S. stock exchange (e.g., New York Stock Exchange) and cash equivalents. Collectively, we refer to ETFs, Funds, and equities as “Securities”. In addition to accounts held at traditional custodians, we also provide discretionary investment management to clients who have a variable annuity or held-away Account, like an individual 401(k) account. We refer to this scenario as a “Sub-Account Overlay”. In order to engage us to manage a non-fee based variable annuity whereas a commission was paid to a Financial Professional for the sale of the variable annuity, a client must hold the variable annuity contract for one (1) year. Due to the often-limited investment options, investment performance may differ significantly from a traditional brokerage Account. Due to investment and operational limitations certain Strategies or Portfolios may not be available as a Sub-Account Overlay. Please ask your Financial Professional for further information. Quartz Partners Form ADV Part 2A: Firm Brochure 5 Clients are allowed to impose reasonable restrictions in accordance with their values, beliefs, or unique situation on the Services we provide and the investment management of their Account. If a proposed restriction is determined to be unreasonable, or we believe is not in the client’s best interest, we will request the client to modify or withdraw the restriction. At our sole discretion, we reserve the right to end an advisory relationship if we believe a client-imposed restriction is detrimental. We are not obligated to buy, sell, or recommend to our clients any security or other investment that we may buy, sell, or recommend for any other clients or for our own accounts. If we obtain material, non-public information about a Security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client and will not use it for our or any client’s benefit. The simultaneous management of the different investment advisory services offered below creates certain conflicts of interest, as the fees for the management of certain types of Services are higher than others. Nevertheless, we seek to treat all such Accounts fairly and equitably over time and model-based Strategies aid in mitigating this conflict of interest. Model-Based Investment Strategies The Strategies below are our core Strategies and are not inclusive of all Strategies that may be offered or developed, including custom Strategies developed as requested. There is no guarantee that our goals will be achieved. Our Investment Committee may periodically rebalance Strategies or portfolios to keep them within model allocation targets. For additional information regarding each model please refer to the corresponding fact sheet and GIPS presentation. Quartz Core Strategies These Strategies primarily employ top-down analysis and active or tactical asset allocation in an effort to identify investment opportunities and risks. A top-down approach begins with analysis of Monetary Policy, Fiscal Policy, Economic Conditions, Earnings, Inflation, Interest Rates, Liquidity, Credit, and Market Dynamics. Market Dynamics measures such things as momentum, value, and investor sentiment. The resultant findings are the main driver of the asset allocation decisions within our Strategies. Technical analysis may be employed at times to seek inflection points, identify overbought and oversold conditions, and to conduct relative strength analyses. Using these inputs, we create Security allocations within the parameters of each Strategy. The general asset class mix is typically the first decision, i.e., the strategy allocations to ETFs, Funds, equities, and cash. Then, decisions are made on factors including but not limited to market capitalization, momentum, style, sector, geography, and credit quality. There are no minimum allocation parameters for any asset class, sector, or style. For example, if we determine that large cap stocks are more attractive than small cap stocks, we may maintain a 0% weighting in small cap stocks. Rather than a predetermined rebalancing schedule, Strategies are monitored and evaluated on a dynamic, ongoing basis. They will be modified (re-allocated or traded) when our Investment Committee determines that such a change is warranted based on changes to the market and/or economic outlook. Our Strategies do not attempt to target a particular level of risk over short periods. Instead, flexible risk levels are undertaken with a goal of aligning strategies with their stated risk objective over a full market cycle, which typically lasts more than 7- years. For example, a Strategy defined as having a moderately conservative risk profile over a full market cycle may at times be invested in line with an aggressive risk profile over a certain market period. Therefore, Clients should carefully consider their particular risk tolerance and have a time horizon of no less than 5-years to capture as much of a market cycle before investing in our Strategies. Quartz Strategy Name Description Benchmark1 Risk Target Quartz Equity Global Tactical Equity 100% MSCI ACWI Moderately Aggressive Quartz Spectrum Global Tactical All-Asset 60% MSCI ACWI / 40% Bloomberg US Aggregate Bond Moderate Quartz Yield Plus Global Tactical Fixed Income Bloomberg US Aggregate Bond Moderately Conservative Quartz High Yield Legacy Global Tactical High Yield Bond Bloomberg US Corporate High Yield Bond Moderately Conservative Quartz Partners Form ADV Part 2A: Firm Brochure 6 1Our strategies do not seek to track a particular benchmark. We have included benchmarks, including the risk benchmark, for reference purposes only to aid in understanding the overall risk profile and investment style of the Strategies. Asteria Core Strategies These Strategies primarily invest in individual U.S. stocks diversified across various market sectors within their relative benchmark. The portfolios are focused, typically holding 20 to 25 stocks and target an annual portfolio turn-over less than 50%. The Asteria Strategies have a primary goal of long-term capital appreciation with a secondary emphasis on reduced volatility. Portfolio construction utilizes a bottom-up analysis with active stock ranking process utilizing a repeatable process that allows our Investment Committee to have both a strict buy process and a specific, disciplined sell process as well. The Investment Committee analyzes a diverse set of fundamental factors to search for companies that demonstrate strong fundamentals relative to their peers and industry. Ultimately our selection process focuses on identifying value-creating firms through understanding the key drivers of corporate performance and market valuations by measuring the return a company earns relative to its actual cost of capital. When evaluating corporations, three key aspects are considered 1) the cash flow the firm is generating; 2) the capital base employed to produce the cash flow; and 3) the opportunity cost of employing the relevant capital. The connection of firm cash flow generation to the assets used to produce the cash flow links the balance sheet to the income statement allowing for more accurate identification of value. Please note that the Asteria Developed Markets Equity strategy invests in different regions throughout the globe excluding the U.S., and gains exposure using a diversified mix of ETF’s rather than individual stocks. Asteria Strategy Name Description Benchmark Risk Target Asteria US Dividend Equity U.S. Large Value Stock Russell 3000 Value Moderately Aggressive Asteria US Core Equity U.S. Large Stock Russell 3000 Aggressive Asteria US Growth Equity U.S. Large Growth Stock Russell 3000 Growth Aggressive Asteria Equity Commodity U.S. Stock Strongly Linked to Commodities S&P GSCI Aggressive Asteria Developed Markets Equity Foreign Stock MSCI EAFE Aggressive Multi-Strategy Portfolios Our multi-strategy Portfolios are built at the investment team’s discretion through allocations to multiple Strategies to provide a more diversified and targeted total portfolio solution for the Client’s unique investment risk target to help balance risk and return. Each target-risk portfolio offers an all-inclusive portfolio solution which seeks positive total returns within its asset class and risk constraints. We periodically rebalance adaptCORE Portfolios to maintain target percentages; however, the timing of rebalances is at the discretion of our Investment Committee. adaptCORE Portfolio Risk Benchmark (full cycle) Primary Blended Index Benchmark MSCI ACWI Barclays US Aggregate Bond Aggressive Growth Aggressive 85% 15% Long-Term Growth Moderately Aggressive 70% 30% Balanced Growth Moderate 50% 50% Conservative Growth Moderately Conservative 15% 85% Quartz Partners Form ADV Part 2A: Firm Brochure 7 Benchmark Descriptions Please note that Strategy indexes and benchmarks described herein are unmanaged, do not incur management fees, costs, and expenses, and cannot be invested in directly.
• Bloomberg Capital U.S. Aggregate Bond Index: comprised of approximately 6,000 publicly traded bonds including U.S Government, mortgage-backed, corporate, and Yankee bonds with an approximate average maturity of 10 years.
• Bloomberg Capital U.S. Corporate High Yield Bond Index: measures the USD-denominated, high yield, fixed- rate corporate bond market. Securities are classified as high yield if the middle rating of Moody's, Fitch and S&P is Ba1/BB+/BB+ or below.
• MSCI ACWI: maintained by MSCI, Inc. and is stock index designed to track broad global equity-market performance. It comprised of stocks from 23 developed countries, including the U.S. and 25 emerging markets.
• MSCI EAFE: maintained by MSCI, Inc. and is a stock index that is designed to measure the equity-market performance of 21 developed markets outside of the U.S. and Canada. EAFE acronym stands for Europe, Australasia and Far East.
• Russell 3000: capitalization-weighted stock market index that seeks to be a benchmark of the entire U.S. stock market. It measures the performance of the 3,000 largest publicly held companies incorporated in America as measured by total market capitalization and represents approximately 97% of the American public equity market.
• Russell 3000 Growth: market capitalization-weighted index based on the Russell 3000 index. The Russell 3000 Growth Index includes companies that display signs of above-average growth, higher price-to-book ratios, and higher sales per share.
• Russell 3000 Value: market capitalization-weighted index based on the Russell 3000 index. The Russell 3000 Value Index includes companies that display signs of value stocks with relatively lower price-to-book ratios, and lower sales per share
• S&P GSCI Index: maintained by S&P Down Jones Indices and serves as a benchmark for investment in the commodity markets and as a measure of commodity performance over time.
• Morningstar Target Risk Index: A family is designed to meet the needs of investors who would like to maintain a target level of equity exposure through a portfolio diversified across equities, bonds, and inflation-hedged instruments. The Morningstar Aggressive Target Risk Index seeks approximately 95% exposure to global equity markets. The Morningstar Moderately Aggressive Risk Index seeks approximately 80% exposure to global equity markets. The Morningstar Moderate Risk Index seeks approximately 60% exposure to global equity markets. The Morningstar Moderately Conservative Risk Index seeks approximately 40% exposure to global equity markets. Institutional Services We offer the following investment advisory services through Platform Sponsors (e.g., investment advisors, broker-dealers, turnkey asset management platforms, custodians, recordkeepers, financial institutions and other financial professionals), for their Private Clients benefit. A Platform Sponsor is an RIA, Custodian, or FinTech company in the business of providing an investment marketplace or platform for Financial Professionals to provide their clients access to investment Strategies of various Third-Party Managers or Sub-Advisors (collectively “Institutional Money Manager”) as well as other Securities in a single unified managed account ("UMA"). A Third-Party Manager or Sub-Advisor is a registered investment adviser that manages one or more investment Strategies for clients like you to invest in. A Strategy is similar to a mutual fund in that it is an asset allocation model with a stated investment objective, clearly defined investment philosophy and/or portfolio construction process, that invests in a portfolio of Securities. However, unlike a mutual fund, Strategies are not required to adhere to the Investment Company Act of 1940, they are not a pooled investment vehicle, and are generally unconstrained in the Securities they can use, and they do not have a prospectus or trustees that govern it. When only one institutional money manager's strategy or asset allocation model is utilized in an account it is referred to as a "Separately Managed Account" or "SMA". In addition to Platform Sponsors performing initial and ongoing due diligence of each of the available institutional money managers and their strategies, Platform Sponsors provide administrative support, trading, performance reporting,

and online client portals among other services for the fee they charge. Similar to a mutual fund, typically each Institutional Money Manager selected by your advisor will have their own investment management fee that may be separate and distinct from the Platform Sponsors fee and your adviser’s fee. While your adviser will typically have discretion over selecting the investment strategies or other Securities, the Platform Sponsor and the Institutional Money Manager selected maintains trading discretion as it pertains to the price, quantity, timing, and what securities to buy or sell in your investment account. Quartz Partners Form ADV Part 2A: Firm Brochure 8 TAMP Program We sponsor a Turnkey Asset Management Platform (hereafter “TAMP”) through which investment adviser firms and Financial Professionals may engage Quartz Partners to serve as a Institutional Money Manager, and provide back-office operational support, reporting, trading, and/or gain access to allocate all or a portion of their underlying client’s assets on a discretionary basis among Quartz Partners investment Strategies. Through collaboration with their Financial Professional, clients will be invested into one or more investment Strategies, or Portfolios. The Financial Professional retains responsibility for the underlying client relationship, including the initial and ongoing suitability determination and recommendation of the appropriate investment portfolio. We shall be authorized, without prior consultation with the Financial Professional or underlying client, to buy, sell, trade, or allocate the underlying client’s assets in accordance with the underlying investment strategies objectives and mandates. From time-to-time, a custom Strategy or investment portfolio based on a client’s request, or their unique circumstance may be designed and implemented. Unless otherwise stated, our TAMP Service requires that Clients grant our firm investment discretion, which Clients may terminate at any time. Model Delivery Program Through collaboration with the Client, the Financial Professional bears the responsibility for determining the ongoing client investment objectives, risk tolerance, and recommendation of the appropriate Strategy, Portfolio, or sub-advisor selected by the Financial Professional. Under the Model Delivery Program, client Accounts will be held at a qualified custodian with whom the Financial Intermediary responsible for sponsoring the platform (hereafter “Platform Sponsor”) has an established relationship. Financial Professionals are generally granted discretion by the client and the responsibility to select and terminate both sub-advisors and the specific Strategy or Portfolio with which the client is invested. Under normal circumstances we are granted limited investment discretion to provide ongoing Strategy allocations and trading instructions pertaining to our specific investment Strategies the Platform Sponsor is offering its clients. We have an ongoing responsibility for investment decisions, security selection, day-to-day portfolio management of the assets, along with helping to continuously monitor and manage the client Account congruent with the Strategy or Portfolio selected. Generally, unlike the TAMP Program, the Platform Sponsor maintains ultimate trading discretion and the responsibility for the timing and execution of our recommended allocation changes and trading instructions. Due to operational feasibility, no custom Strategies or investment portfolios based on a client’s request, or their unique circumstance are offered. Investment Company Portfolio Manager Program We offer portfolio manager or sub-adviser Services to Funds and/or ETFs. For these services we may manage one or more of the following: investment decisions, Security selection, day-to-day portfolio management of the assets, and/or the timing amount and manner in which to effect Securities transactions. Full investment discretion is typically granted. O-CIO Program As an Outsourced Chief Investment Officer, or “O-CIO”, we can provide ongoing investment research, investment related communications, general security selection and portfolio investment strategy recommendations for a fixed monthly subscription fee. For this service, we do not have the authority to execute any security transactions or have investment discretion over any investment account. Subscribers to this service are under no obligation to implement any recommendations provided by our Investment Committee and this service. Digital Investing Program We offer Clients an automated online and digital investing platform marketed as adaptvest. Services for this program are delivered predominantly through the firm’s website, client portal and/or mobile application (collectively “firm Site”). This program does not provide advice in person or over the phone in any manner. All client communications and contacts will occur through email, the firm Site, or other similar digital means. The firm does remain available to provide phone support for non-investment advice related issues like compliance questions, customer support, service requests, and technical issues. Accounts are opened digitally through a website with the execution of Agreements and Account documents through electronic signatures and certifications. Clients subscribing to this Program will authorize our firm investment discretion to invest client Accounts based on the results of their risk profile questionnaire which will be managed based on composition of the Portfolio along with the objectives and mandates of the underlying Strategies. Clients are required to have their Account held with a Custodian selected by our firm that is compatible with the requirements of this Program which includes, but is not limited, to digital account opening and funding. No custom Strategies or investment portfolios based on a client’s request, or their unique circumstance are offered. Please understand that this Program is Quartz Partners Form ADV Part 2A: Firm Brochure 9 not as comprehensive as other Services and Programs available through our firm or other Financial Professionals and Financial Intermediaries. Employer Retirement Plan Services We provide investment advice, certain administrative oversight, and consulting services to employer sponsored retirement plans (hereafter “Retirement Plan”). We offer the following Retirement Plan Services as either a turn-key comprehensive solution or a la carte: Non-Fiduciary Services Monitoring and Reporting Key Metrics: Performance monitoring and reporting to assist Plan Sponsor in making sure investment decision making adheres to the plan’s investment policy statement and identify areas of concern. Plan Design: Aiding the Plan Sponsor in determining the unique needs, requirements, and goals of the Retirement Plan. Provider Search and Selection: Assisting the Plan Sponsor in the fiduciary obligation of evaluating, selecting, and implementing provider services. We can oversee, negotiate, and maintain relationships with plan providers. Education: We provide educational support to both Plan Sponsors and participants which includes advising them on the Retirement Plan’s investment options, features, benefits, online account access, regulatory updates, enrollment, and servicing paperwork. Any investment recommendations so provided will be based on information relating to age, time horizons (e.g., life expectancy, retirement age), risk tolerance, current investments in designated investment options, other assets or sources of income, and investment preferences of the participant or beneficiary. Investment advice will not include monitoring or rebalancing of a participant’s portfolio unless the participant is invested in one of our Strategies. Fiduciary Services. Investment Policy Statement: A customized written Investment Policy Statement (hereafter “IPS”) will be drafted that roadmaps the investment methodologies, objectives, asset class guidelines, performance monitoring, duties and responsibilities, implementation of investment options, and expense monitoring of the Retirement Plan. Designated Investment Alternatives (“DIAs”) Investment Menu: Prudent investment recommendations and ongoing monitoring of Retirement Plan investment options, including a qualified default investment alternative (hereafter “QDIA”). Investments shall be monitored and replaced when appropriate using a repeatable process. Model Asset Allocation Portfolios: Our Strategies and/or Portfolios will be made available to Participants as a means of more efficiently delivering investment advice to Participants. When a Participant selects one of our Strategies and/or Portfolios, we have an ongoing responsibility for investment decisions, security selection, day-to-day portfolio management of the assets, and/or the general timing in which to effectuate securities transactions. Disclosures Specific to Retirement Plan Accounts and IRAs Retirement Plan Consulting Limited Scope of Advice and Discretion: We do not provide nor have any responsibility to provide any Services with respect to the following: employer securities, real estate, non-publicly traded securities or assets, illiquid investments, legal or tax advice. Further, unless we agree in writing to be appointed as a discretionary ERISA 3(38) investment manager, our recommendations are non-discretionary and will only be implemented at the Plan Sponsor’s sole discretion. ERISA Disclosure: We will disclose any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(iv) as soon practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable). Further, in accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or plan administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Retirement Plan agreement and any compensation or fees received in connection with the agreement that is required for the Retirement Plan to comply with the reporting and disclosure requirements of Title 1 of Quartz Partners Form ADV Part 2A: Firm Brochure 10 ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section2550.408b-2(c)(1)(iv) or (vi), we will disclose to the Retirement Plan the correct information as soon as practicable, but no later than thirty (30) days from the date on which we identify such error or omission. Retirement Plan Rollover and IRA Recommendations: A recommendation to take a distribution from an employer sponsored retirement plan or to transfer (or withdraw from) an IRA are fiduciary acts. Providing education regarding distribution options is an important consideration for selecting among those options. To the extent a rollover is recommended from a client’s employer sponsored retirement plan or existing IRA to an IRA managed by our firm please know that this presents a conflict of interest. As with any Account we have an economic incentive due to increased advisory fees. You are under no obligation, contractually, or otherwise to rollover or transfer your retirement account. To mitigate this conflict of interest we have adopted an impartial conduct standard whereby our we will provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below:
• Not recommend investments which result in our firm receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA;
• Fully disclose compensation received by our firm and any material conflicts of interest;
• Follow policies and procedures designed to ensure that we give advice in our client’s best interest and avoid putting our financial interests ahead of our clients when making recommendations;
• Charge no more than is reasonable for our Services;
• Refrain from making any materially misleading statements about conflicts of interest, fees, and investments; and
• Meet a professional standard of care when making investment advice by acting with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of our firm or our affiliated personnel. A decision to move and invest assets from an IRA or former employer’s qualified retirement plan (i.e. 401(k), 403(b), 457(b), etc.) is an important one. If you retire or otherwise leave your employer there are several factors to when determining what option best fits your individual needs and objectives. Factors include among others, tax implications, changes in account features and consider differences in fees and expenses. Please discuss this with your Financial and Tax Professionals. Wrap Fee Programs Our firm does provide certain advisory services through a Wrap Fee Program (hereafter “Wrap Program”). Under this Wrap Program, clients generally pay a single fee that covers both advisory services provided by our firm and brokerage services provided by Charles Schwab an unaffiliated broker-dealer. Charles Schwab receives a portion of the wrap fee associated with brokerage transactions in your Account. When you work with a Financial Professional that is not registered with our firm, you will be charged a separate fee for their services. While Charles Schwab & Co, Inc. (“Schwab”) offers commission free trading of ETF’s, individual stocks, and bonds, they do charge a fee when we buy or sell a transaction-fee mutual fund within your Account. This Wrap Program is designed for our firm to pay the fee charged by Schwab associated with buying and selling transaction-fee mutual funds within your Account. Wrap pricing structures allow you to pay an all-inclusive fee for management, brokerage, clearance, custody, and administrative services. The benefits under a wrap fee program depend in part, upon the size of the Account, the costs associated with managing the account, and the frequency or type of Securities transactions executed in the Account. For example, a Wrap Program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities, or no-transaction-fee mutual funds, or any other type of Security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap or bundled fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program with the amounts that would be charged by other advisors, broker-dealers, and qualified custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Program. Our firm also participates in a Wrap Program as an investment or model manager. In this scenario we offer our Strategies and Portfolios through our Institutional Sub-Advisor or Third-Party Manager Service to Clients of Financial Intermediaries who may Quartz Partners Form ADV Part 2A: Firm Brochure 11 sponsor a Wrap Program (“Platform Sponsor”). Our participation in these Wrap Programs pays our firm a flat asset-based advisory fee in return for providing the investment management component of the Wrap Program. Generally, the Financial Professional will receive their advisory fee as a portion of the Wrap Program Fee. Clients participating in a Wrap Program will sign a separate agreement and receive a Wrap Fee Program Brochure from the Platform Sponsor. You should note that the same (or similar) services as those described above may be available from other sources at a lower cost to you. Depending upon the level of the wrap fee charges, the amount of portfolio activity in your account, the value of services that are provided, and other factors, a wrap fee may exceed the aggregate cost of services if they were to be provided separately. Generally, wrap programs are relatively less expensive for actively traded accounts. However, a non-wrapped pricing arrangement may be more cost effective for accounts that do not experience frequent trading activity. Accordingly, firms sponsoring a Wrap Fee Program have a conflict of interest because we have financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your Account(s) subject to a wrap fee. Assets Under Management As of December 31, 2023, we receive fees on a total of $251,414,069 of client assets. Of this, we managed $208,012,740 in discretionary assets under management. The remaining $43,401,329 are non-discretionary assets under management in which we do not have full investment trading discretion. These non-discretionary assets under management are typically Model Delivery Program, employer sponsored retirement plans where our firm only serves as a 3(21) fiduciary or for accounts utilizing the services of an unaffiliated third-party manager or sub-advisor.