A. Ownership/Advisory History Copper Beech Financial Group, LLC (“CBFG” and/or “the firm”), is a limited liability company organized in the state of New Jersey. The firm was formed in December 2009, and the principal owner is CB Tree Holdings. Castle Reinsurance controls CB Tree Holdings. John Parise is the CEO of CBFG, and Michael Parise is the CCO of CBFG. B. Advisory Services Offered Portfolio Management Services CBFG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CBFG creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:  Investment strategy  Personal investment policy  Asset allocation  Asset selection  Risk tolerance  Regular portfolio monitoring CBFG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CBFG will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CBFG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CBFG’s economic, investment or other financial interests. To meet its fiduciary obligations, CBFG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CBFG’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CBFG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. For its discretionary asset management services, CBFG receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this brochure. CBFG’s discretionary asset management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. CBFG will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances. In addition, CBFG may utilize third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio (to be noted on the client agreement), and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. CBFG will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. CBFG will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Financial Audit Services We will conduct an initial analysis of your current financial circumstances, assets, liabilities, current and projected sources of income, business goals, and related matters. As part of these services, we will provide you an initial report to summarize and analyze your assets, cash flow projections, and considerations related to risk management and general tax considerations and other initial observations. Please see Item 5 for information on fees for these services. As part of the financial audit services, we will not make specific recommendations or advice to the client, and any advice or recommendations intended to be tailored to the client will only be provided if we are engaged to provide additional services to the client. Based on, or together with, the Financial Audit Services, the client may elect to engage us to perform and provide other services identified in the client agreement. Information evaluated as part of the audit include the following:  Balance Sheet & Net Worth Statement
• Asset projections  Business Succession Observations
• Buy/Sell Agreement Review  Investment Portfolio Observations
• Review of current portfolio
• Review risk/reward profile
• Review of current allocation
• Review sector analysis  Cash Flow
• Budgeting and cash flow analysis
• One Retirement cash flow projection  Risk Management
• Review annuities
• Life insurance analysis

• Disability analysis
• Long-term care analysis
• Property & casualty analysis  Family Governance & Succession  Estate Planning
• Review of existing estate documents
• Probate avoidance
• Asset protection analysis
• Projected estate tax liability
• Death tax funding
• IRC Section 6166 analysis Third-Party Money Managers As part of our investment advisory services, we may recommend a third-party money manager to manage a portion of the client's investment portfolio. Factors we take into consideration when making our recommendation include, but are not limited to, the third-party manager’s performance, investment strategies, methods of analysis, advisory fees and other fees, assets under management, and the client's financial objectives and risk tolerance. We would generally retain authority to hire/fire the third-party manager, and we regularly monitor the performance of the manager to ensure its management and investment style remain aligned with the client's objectives and risk tolerance. CBFG continuously manages any third-party manager relationship and continuously monitors the client's account(s) for performance metrics and adherence to the client's ISP. Each third-party manager maintains a separate disclosure document that will be provided directly to the client by CBFG. The client should carefully review the third-party manager’s disclosure document for information regarding fees, risks and investment strategies, and conflicts of interest. The third-party manager will charge fees to the client, which fees will be in addition to the fees charged by CBFG. Financial Planning CBFG provides personalized, confidential financial planning. Advice is provided through consultation with the client. CBFG 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 toward risk. Related documents supplied by the client are carefully reviewed. Clients will receive a comprehensive written plan that will outline general recommendations for a course of activity or specific actions to be taken by the clients. Based on the client’s needs, financial planning services generally include any or all of the following:  Income Tax Management & Analysis  Retirement Planning  Employee Benefits Planning  Cash Flow Planning  Risk Management; Insurance Evaluation  Investment Planning; Portfolio Evaluation and Asset Allocation Planning  Higher Education Planning  Estate Planning  Business Financial Planning  Meeting(s) with Third-Party Professional Advisors Family Office Services CBFG provides a suite of family office services as applicable to each client’s personal and financial circumstances. Clients may choose one or all of the following services:  Next Generation Advice  General Family Office Services
• Advanced Estate Planning & Design
• Asset Protection Planning
• Business Succession Planning & Design
• Investment Account Analysis/ Oversight
• Investment Manager Due Diligence
• Life Insurance Audit & Policy Design
• Year-End Tax Planning with CPA
• Personal Cash Flow Management
• Philanthropic Planning
• Special Needs Planning
• Personal/Business Risk Management
• Nationwide Advisor Network
• Family Advisor Collaboration
• Multi-generational Advisor
• Capital Sourcing & Management
• Family Mission Statements Creation
• Family Legacy Letters Creation
• Family Governance Creation
• Family Investment Policy Statements
• Annual Intergenerational Family Meetings
• Ongoing Asset Monitoring
• Project Task Management
• Quarterly Meetings & Reports
• Annual Educational Symposium Ongoing Consulting Services CBFG may contract with clients to provide consulting services on various topics. CBFG will acquire information concerning the client’s assets, liabilities, present and future foreseeable obligations, present and future income requirements, client’s desired financial goals and client’s tolerance for risk as well as any other information that is applicable. C. Client-Tailored Services and Client-Imposed Restrictions CBFG will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by CBFG on behalf of the client. CBFG may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. 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 CBFG from properly servicing the client account, or if the restrictions would require CBFG to deviate from its standard suite of services, CBFG reserves the right to end the relationship. D. Wrap Fee Programs CBFG does not participate in wrap fee programs, where brokerage commissions and transaction costs are included in the asset-based fee charged to the client. E. Client Assets Under Management As of December 31, 2023, CBFG managed $112,554,400 of discretionary assets and $0 of non- discretionary assets.