Page 5 A. James T. Borello & Co. James T. Borello & Co. (“JTB” and/or “the firm”), is an registered investment adviser principally owned by Daniel J. Borello. James T. Borello & Co. has been offering financial planning and investment advisory services since 1992. James T. Borello is the President and Chief Compliance Officer of the firm. B. Advisory Services Offered JTB is an independent investment advisory and financial planning firm offering a variety of financial services to individuals, high-net-worth individuals, small businesses, trusts, and other legal entities. Advisory services may include financial planning, retirement and education planning, investment recommendations, tax preparation and planning, insurance planning, elder care, and estate planning. All financial planning and investment advisory services are provided on a discretionary basis. JTB recommends securities transactions to its clients that include securities and strategies as described in Item 8 of this Brochure. B.1. Financial Planning Services JTB’s financial professionals help clients make financial arrangements for a variety of life circumstances including: § Retirement Planning. JTB considers both your goals for the future and your current financial situation and responsibilities, as well as the following factors:
• Your current level of debt
• Your household operating budget
• How much you have saved in retirement plans like 401(k)s and IRA
• How much you can afford to contribute to your retirement plans now and into the future
• How much you will need to live on annually during retirement
• Your homeownership situation
• Your educational savings goals
• Your estate planning objectives § Education Planning. JTB advises on various savings vehicles for education as well as traditional investment accounts. We examine your current financial situation and your long-term savings objectives to craft an investing strategy that works for you. § Insurance Planning. We integrate all insurance decisions into your long-term financial plans and overall tax strategy. There are many different types of insurance available to the consumer, but some are decidedly more important than others, including:
• Health Insurance - Unexpected medical bills can devastate a financial plan. A serious illness or injury can quickly consume your savings. Everyone needs health insurance.
• Life Insurance - If you have dependents, life insurance is an absolute necessity. Should anything happen to you, life insurance benefits will financially protect your Page 6 dependents. Additionally, life insurance can have some excellent investment potential, and some types of life insurance policies offer tax advantages.
• Disability Insurance - If you are unable to work because of illness or injury, disability insurance replaces your income so you do not have to suffer financially. Without it, your savings can suffer just to pay your everyday expenses.
• Long-Term Care Insurance - If you require in-home care, nursing home care, or assisted living in your senior years, long-term care insurance will cover the cost. Most people do not realize how expensive eldercare expenses can be. Long-term care insurance protects your retirement nest egg and exempts your relatives from the financial burden of your care. § Estate Planning. JTB will provide advice on how various retirement planning vehicles can be used to maximize the value of your estate. In addition, JTB provides recommendations on tax strategies to help maximize the value of your estate. § Eldercare. JTB will work both with children of aging parents and individuals interested in pre-planning for their own care. We explore a variety of options and work with you to make sure both your financial

and care needs are met. JTB gathers required information through in-depth personal interviews and questionnaires. Information gathered includes a client's current financial status, investment objectives, future goals, and attitudes towards risk. Related documents supplied by the client are carefully reviewed, for purposes of providing recommendations covering one or more of the above-mentioned topics as directed by the client. Clients will receive a written or oral report (depending on the client’s preference) providing them with a detailed financial plan designed to help achieve their stated financial goals and objectives. B.2. Investment Advisory Services JTB’s discretionary investment advisory services includes providing clients with investment recommendations to create diversified portfolios that include securities and strategies described in Item 8 of this brochure. In preparing the recommendation, JTB will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance. JTB’s objective is to review the client’s tax and estate planning objectives and goals in connection with the client’s investment objectives, goals, tolerance for risk, and other personal and financial circumstances and make appropriate recommendations. In addition, JTB may utilize third-party software to analyze individual security holdings utilized within the client’s portfolio. JTB's investment advisory services to clients are based on asset allocation models that, as noted above, take into account a client's personal financial circumstances, investment objectives, and tolerance for risk (e.g., cash-flow, tax, and estate). JTB's engagement with a client will include, as appropriate, the following: § Providing assistance in reviewing the client's current investment portfolio against the client's personal and financial circumstances as disclosed to JTB in response to a questionnaire and/or in discussions with the client and reviewed in meetings with the firm. § Analyzing the client's financial circumstances, investment holdings and strategy, and goals. § Providing assistance in identifying a portfolio design. § Recommending securities as outlined in Item 8 for consideration by the client. In addition to providing JTB with information regarding their personal financial circumstances, investment objectives, and tolerance for risk, clients are required to provide the firm with any Page 7 reasonable investment restrictions that should be imposed on the management of their portfolios and to promptly notify JTB of any changes in such restrictions or in their personal financial circumstances, investment objectives, goals, and tolerance for risk. Also Clients may engage JTB to manage and/or offer investment advice on certain investments that are not maintained at their primary custodian, such as assets held in qualified tuition 529 plans. In these situations JTB directs or recommends the allocation of client assets among the various investment options available in each plan/custodian. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account - for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs JTB does not sponsor a wrap fee program; nor is JTB a Portfolio Manager of a wrap fee program. E. Client Assets Under Management As of September 30, 2023, JTB has the following assets under management: Discretionary: $323,690,098 Non-Discretionary: $ 0 Item 5: Fees and Compensation