A. FIRM DESCRIPTION Sage Tree Wealth, Inc. (“STW” or the “Adviser”) is an investment management firm that is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser. The Adviser is organized as a New York corporation that was founded in 2018 and registered as an investment adviser as of January 1, 2019. STW’s current business activities consist primarily of the discretionary management of securities portfolios. Owner: Daniel A. Monte is the President and Chief Compliance Officer and the sole owner, owning 100% of the Adviser. B. TYPES OF ADVISORY SERVICES INVESTMENT MANAGEMENT STW offers personalized investment advisory services to individuals, pension and profit- sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. STW offers investment management services which are focused on capital appreciation. The Firm’s primary approach is to use a tactical allocation strategy aimed at reducing risk and increasing performance. The Firm measures and selects mutual funds and individual stocks by using various criteria, such as the fund manager’s tenure, and/or overall career performance. The Firm may recommend, on occasion, redistributing investment allocations to diversify the portfolio to reduce risk and increase performance. The Firm may recommend specific stocks and ETFs to increase sector weighting and/or dividend potential. The Firm may recommend employing cash positions as a possible hedge against market movement which may adversely affect the portfolio. The Firm 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, overvaluation 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. STW offers custom management of portfolios in two distinct programs, the STW Advisory Account Program – Discretionary, and STW Advisory Account Program – Non- Discretionary, according to the client’s objectives. STW Advisory Account Program – Discretionary: As a discretionary adviser, STW will have the authority to supervise and direct the client’s portfolio without prior consultation with the client. Notwithstanding the foregoing, clients may impose certain written restrictions on STW with the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments. Each client should take note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. STW Advisory Account Program – Non-Discretionary: Alternatively, STW provides non- discretionary portfolio management services whereby the Firm will make specific investment recommendations to a client tailored to meet the needs and investment objectives of that specific client but shall not initiate any orders to purchase or sell any securities (or specific securities) without the client’s approval. STW requires that a written Investment Advisory Agreement (“IA Agreement”) be signed by the client prior to the provision of services. The IA Agreement outlines the services rendered by STW and the fees clients will be charged. As noted above, clients shall open either a discretionary asset management account or a non-discretionary account with the Custodian, through which STW shall monitor the assets of the Account, and purchase and/or sell securities on a discretionary basis within the Account, according to the terms and conditions of the IA Agreement. THIRD PARTY MONEY MANAGERS STW also provides access to investment service programs in which client accounts are managed by independent third-party investment advisers. Our Firm has entered into agreements with various third parties’ investment advisers to offer for the purpose of having their products and services available to our clients. These programs provide investment opportunities among mutual funds, variable annuities, stocks, bonds, and additional securities. STW will assist clients in determining the appropriate allocation of the client’s invested assets among different asset classes, and in turn may select one or more third-party money managers who specialize in each of those asset classes. Our Investment Adviser Representatives (“IAR”) meet with clients to analyze the client’s need(s) of third-party advisory programs or services by collecting the client’s financial information including the client’s suitability. Based on the information provided by the client, STW will assist the client in determining an appropriate asset allocation amount available with independent third-party money managers based on the investment style and asset classes employed by those money managers. clients will receive a separate Form ADV Part 2A of each selected third- party money manager and will enter into a separate investment management agreement with each third-party money manager selected by STW. The third-party manager will be granted discretionary trading authority to provide investment supervisory services for that portion of the client’s portfolio allocated to that particular third-party money manager. Under this arrangement, STW does not make any custody arrangements for the client’s funds and securities. The money managers will trade independently of one another. There can be no assurance that the trading strategies employed by a third party money manager will be successful. clients are encouraged to obtain and carefully review the contracts and disclosure documents, including Form ADV Part 2A, of the third party money managers whose services they are considering so they understand fully the services being provided and the fees being charged. The services, reports and contract termination provisions provided by these programs vary as do the costs. We encourage our clients to compare programs.
FINANCIAL PLANNING SERVICES STW engages in broad-based, modular, and consultative financial planning services. Broad- based financial planning advice will typically

involve providing a variety of services, principally advisory in nature, to clients regarding the management of their financial resources based upon an analysis of their individual needs. An IAR of STW will first conduct a complimentary initial consultation. After the initial consultation, if the client decides to engage STW for financial planning services, an IAR will conduct follow up meetings as necessary, during which pertinent information about the client’s financial circumstances and objectives is collected. Once such information has been reviewed and analyzed, a written or oral financial plan – designed to achieve the client’s stated financial goals and objectives – will be produced and presented to the client. For clients requiring advice on a single aspect of the management of their financial resources, STW offers financial plans in a modular and/or consultative format that address only those specific areas of interest or concern. PENSION CONSULTING SERVICES STW will provide pension-consulting services to employee benefit plans and their fiduciaries based upon an analysis of the needs of the plan. In general, these services may include an existing plan review, asset allocation advice, money management services, communication and education services where STW will assist the plan sponsor in providing meaningful information regarding the retirement plan to its participants, investment performance monitoring, and/or ongoing consulting. The Adviser may have agreements with third party administrators (“TPA”) to provide these services as part of the TPA’s agreement with the plan. In these instances, the TPA may pay a portion of the fee charged to the plan to STW for their services. In other instances, the Adviser may be introduced to a plan through a TPA and will provide service directly to the plan. STW may hold educational meetings for plan sponsors and employees and may offer one or more of the following education services: seminars; web education; periodic plan reviews; one on one participant meetings; annual plan sponsor due diligence meetings. STW can also meet with individual plan participants and offer personalized information based on their individual objectives. All client accounts are regulated under the Employee Retirement Income Securities Act (“ERISA”). STW will provide consulting services to the plan fiduciaries as described above. Typically, the named plan fiduciary must make the ultimate decision as to retaining the services of such investment advisers as STW recommends. The plan fiduciary is free to seek independent advice about the appropriateness of any recommended services for the plan.
C. TAILORED RELATIONSHIPS INVESTMENT MANAGEMENT STW provides its clients with an overview of investment strategies and explains the risks involved (as noted above and in Item 8). STW will tailor its advisory services to its clients’ individual needs based on meetings and completion of a client profile. If clients wish to impose certain restrictions on investing in certain securities or types of securities, the Firm will address those restrictions with the client to have a clear understanding of the client’s requirements. THIRD PARTY MONEY MANAGERS The selection of third-party money manager is based on individual needs of our clients and the suitability of products and services. Our advice is based on a thorough assessment of our client’s goals, objectives, investment horizon, and risk tolerance and the investment philosophy of the third-party money manager. FINANCIAL PLANNING SERVICES Financial plans are based on the client’s financial situation at the time the plan is presented and are based on financial information disclosed by the client to STW. clients are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. STW cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As the client’s financial situation, goals, objectives, or needs change, the client must notify STW promptly. In limited circumstances, some clients may only require advice on a single aspect of the management of their financial resources. For these clients, STW offers financial plans in a modular format and/or general consulting services that address only those specific areas of interest or concern. clients may act on STW’s recommendations by placing securities transactions with any brokerage firm the client chooses. The client is under no obligation to act on STW’s financial planning recommendations. Moreover, if the client elects to act on any of the recommendations, the client is under no obligation to implement the financial plan through STW. PENSION CONSULTING SERVICES STW will provide pension-consulting services to employee benefit plans and their fiduciaries based upon an analysis of the needs of the plan. D. WRAP FEE PROGRAMS Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and other financial institutions and affiliated and unaffiliated investment advisers through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account.
STW currently provides portfolio management services as part of a wrap fee program for clients utilizing either, Foliofn Investments, Inc. (“Foliofn”) or InteractiveBrokers, LLC as the broker dealer and custodian for their accounts. STW has separate written agreements with Foliofn, and InteractiveBrokers, LLC where clients are charged an all-inclusive fee for advisory, brokerage, and custodial services. E. ASSETS UNDER MANAGEMENT STW manages $ 27,897,730 in regulatory assets under management on a discretionary basis. Total assets under advisement are $ 30,539,303. This figure is based on calculations as of December 31, 2023.