Bleakley is an investment advisory firm providing customized financial planning and wealth management services to a broad array of clients. Bleakley is a limited liability company that was founded in 1994 and is principally owned by Andy Schwartz as he owns more than 25% but less than 50% of the firm. Additional information about Bleakley’s direct owners and executive officers may be found in Form ADV Part 1, Schedule A available at adviserinfo.sec.gov by searching Bleakley’s name or using Bleakley’s CRD #318366. Bleakley is registered as an investment adviser with the SEC. As of December 31, 2023, Bleakley managed $9,176,052,784 in total client assets. Bleakley managed $8,557,716,265 of client assets on a discretionary basis and $618,336,519 of client assets under advisement.1 Bleakley’s financial professionals, called Advisors (also referred to in this Wrap Fee Program Brochure as “Bleakley’s Advisors,” “the Advisor” or “its Advisors”), offer its clients (individuals, business entities, trusts, estates and charitable organizations, etc.) investment advisory services on a discretionary basis. These investment advisory services also include wealth management, retirement plan consulting and advisory, financial consulting and other consulting services to the extent specifically requested by a client. Bleakley Advisors also provide clients investment advisory services on a non-discretionary basis. Clients should discuss with their Bleakley Advisor what roles are appropriate, and what programs are appropriate for their investment objectives and risk tolerances. Bleakley’s General Counsel is available to address any questions that a client or prospective client may have regarding any conflicts of interest associated with any particular program or strategy or any information outlined in this Wrap Fee Program Brochure. Bleakley Wrap Program Services Bleakley is the wrap program sponsor of the Bleakley Wrap Program and participates in wrap fee programs sponsored by other firms. Under the Bleakley Wrap Program, Bleakley is authorized by the client in writing to determine which investments and the amounts of investments that are bought or sold. Such investments include equity and fixed income securities, mutual funds, Exchange Traded Funds (“ETFs”), variable annuities and other pooled investment funds. Such investments may also include custodian-sponsored programs and services, third- party investment manager programs and Turnkey Asset Management Platforms (“TAMPs”). Bleakley works to provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an Advisor will discuss and review each client’s 1 Inclusion of assets under advisement will make the total client assets number different from the total number disclosed in Item 5.F of Bleakley’s Form ADV Part 1A due to specific calculation instructions for “regulatory assets under management.” particular investment objectives and risk tolerances. This information will include, but not be limited to:
• Retirement and financial goals
• Investment objectives
• Investment time horizon
• Financial needs and goals and risk tolerance
• Cash flow analysis
• Cost of living needs
• Education expense needs
• Savings tendencies
• Other applicable financial information required by Bleakley in order to provide the investment advisory services requested Bleakley Advisors allocate each client's investment assets consistent with the client’s designated investment objectives and risk tolerances. Clients may, at any time, impose restrictions, in writing, on Bleakley's services. Each client is responsible for promptly notifying Bleakley of any change in financial situation or investment objectives for the purpose of reviewing and revising Bleakley's previous recommendations and services. Bleakley and its Advisors will be in periodic contact with clients to discuss clients' investments, investment objectives and risk tolerance. Clients should discuss with their Bleakley Advisor what roles and programs are appropriate based on the client’s investment objectives and risk tolerances. For certain accounts, Bleakley utilizes custodian-sponsored programs and services, third-party investment manager programs and/or Turnkey Asset Management Platforms (“TAMPs”). These services may be offered as a separately managed account (commonly referred to as SMAs) or as a unified managed account (or UMAs). Bleakley will provide such custodians, investment manager and TAMPs, as applicable, client-specific information to enable that custodian, investment manager or TAMP to provide the elected services. As part of Bleakley’s investment advisory services, Bleakley Advisors will recommend a custodian that is a broker-dealer and is also a member of FINRA and SIPC to maintain custody of clients' assets and facilitate trades for the clients’ accounts (referred to as “custodians”). Currently, Bleakley utilizes the following custodians:
• LPL Financial, LLC (“LPL”),
• Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”).
• Pershing Advisor Solutions, LLC (“PAS”),
• Fidelity Investments Inc. (“Fidelity”), and
• TD Ameritrade, Inc. (“TD Ameritrade”). Please note: Before selecting a custodian, clients should discuss with their Bleakley Advisor the differing custodial accounts, programs, services, fees and costs. For example, a non-wrap fee is not available for Bleakley clients through LPL or Pershing. Additionally, the custodians offer various third-party investment manager programs. The final decision to custody assets with any custodian is made by Bleakley's clients, including client accounts established under Employee Retirement Income Security Act of 1974, as amended (“ERISA”) or Individual Retirement Account (“IRA”) rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. For more information about these custodians, clients should refer to Investment Advisor Public Disclosure at www.adviserinfo.sec.gov or FINRA BrokerCheck at https://brokercheck.finra.org/. Some investments may be custodied by or through the issuer, for example mutual funds or variable annuity products. Bleakley is independently owned and operated and not affiliated with any custodian; however, certain of Bleakley’s Advisors are also registered representatives of LPL (“dually registered persons”). Clients who engage Bleakley on a discretionary basis may, at any time, impose restrictions, in writing, on Bleakley’s discretionary authority (e.g., limit the types/amounts of particular securities purchased or sold for the account, exclude the ability to purchase or sell securities with an inverse relationship to the market or proscribe Bleakley’s use of margin, etc.). Client restrictions can affect the account’s performance. Bleakley Wrap Program Fees and Compensation Under a Bleakley wrap fee account a client is charged a single or “wrap” fee that includes Bleakley’s investment advisory fee and either the custodial asset-based charge or the custodial transaction-based charges, as applicable. When managing a client’s account on a wrap fee basis, Bleakley receives the balance of the wrap fee after deducting, as applicable, the custodial asset- based charge or the custodial transaction-based charges. Bleakley’s Advisors at their discretion negotiate an annual wrap fee up to a maximum of two percent (2.00%) of assets managed by Bleakley and may apply the following fee schedule: Market Value of Portfolio Annual Wrap Fee % $0 – $500,000 2.00% $500,001 – $1,000,000 1.85% $1,000,001 – $5,000,000 1.70% More than $5,000,000 Negotiable Custodial account and other service fees are not covered by the annual wrap fee, including, but not limited to, mutual fund fees and exchange traded fund charges imposed directly at the fund level (e.g., management fees and other fund expenses), margin interest, account activity fees, and any fee associated with maintaining a retirement account charged by the custodian of the qualified account. Additionally, for wrap accounts held at LPL the client will incur a ticket charge for foreign stocks transactions. Furthermore, Bleakley’s proprietary investment strategy fees and third-party investment manager or sub-advisor fees are not included in the annual wrap fee. Bleakley’s annual wrap fee is negotiated based upon various objective and subjective factors, including, but not limited to, the amount of the assets placed under Bleakley’s direct management, the amount of the assets placed under Bleakley’s advisement (e.g., non- discretionary, held-away or unmanaged account(s)), the complexity of the engagement, and the level and scope of the overall investment advisory services to be rendered by the Bleakley Advisor. Additionally, a Bleakley Advisor may have client relationships that pre-date the Advisor’s association with Bleakley and, as a result, such clients' annual wrap fee may be higher or lower than the schedule outlined above. Bleakley endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic or other benefits by Bleakley in and of itself creates a conflict of interest and may influence Bleakley’s choices for investments, custodial services, third-party investment managers and TAMPs. Additionally, the receipt of economic or other benefits by Bleakley’s Advisors in and of itself creates a conflict of interest and may influence the Advisors’ recommendations to clients. Furthermore, a conflict of interest arises in that Bleakley’s Advisors have an incentive to increase the assets held in a Bleakley advisory account (wrap or non-wrap) as it increases the fee paid to Bleakley and its Advisors. Similarly, a conflict of interest arises in that Bleakley’s Advisors

have a disincentive to trade securities in order to reduce the custodial transaction-based charges in a wrap account, thereby increasing the wrap fee amount retained by Bleakley and its Advisors. Wrap fees and custodial charges may be higher or lower than those charged by other investment advisers. The investment strategy, investments and related transactions will impact whether a client will pay more in a non-wrap versus a wrap fee account. The terms and conditions for client participation in advisory programs or relative to any Bleakley services are set forth in Bleakley's written agreements and the account paperwork for the specific advisory programs or services. All prospective clients should read this Wrap Fee Program Brochure, all relevant brochure supplements, and any documentation for the specific advisory programs or services, and ask any corresponding questions, prior to participation in any advisory program or service provided by or through Bleakley. Participation in the wrap program fees may cost more or less than purchasing such services separately. Wrap program fees may be higher or lower than those charged by other sponsors of comparable wrap fee advisory programs. Additional information is provided below. Clients may inquire at any time with the Bleakley Advisor as to client-specific custodial charges. Custodial Charges: Client-specific custodial asset-based charge or, as applicable, custodial transaction-based charges and custodial account and other service charges are detailed in the client’s custodial agreement(s) or client’s custodial quarterly statements. A general description of such charges is provided below. The investment strategy, investments and related transactions will impact whether a client will pay more in custodial asset-based charge or the custodial transaction-based charges, as applicable. Furthermore, the custodial charges will differ by custodian and may be higher or lower depending on the investment, transaction, or custodial service. As a result, Bleakley’s clients will pay diverse custodial charges that may be higher or lower than those charged by other investment advisers. Custodial Asset-Based Charge: LPL and Schwab offer custodial asset-based pricing. The custodial asset-based charge is paid to the custodian, based on the assets held within the account. The custodial asset-based charge covers various transaction costs, such as mutual fund fees, brokerage commissions and mark-ups/mark-downs for fixed income securities. The investment strategy, investments and related transactions will impact whether a client will pay more in custodial asset-based charge or a custodial transaction-based charge. LPL’s custodial asset-based charge is billed quarterly in arrears and deducted from Bleakley’s wrap fee; Schwab’s custodial asset-based charge is billed monthly in arrears and either deducted from Bleakley’s wrap fee or, as applicable, deducted from the client’s non-wrap fee account. Note: At Schwab, a Bleakley Advisor may, at the Advisor’s sole discretion, choose either custodial asset-based pricing or custodial transaction-based pricing (as discussed below). Clients may inquire at any time with the Bleakley Advisor as to client-specific custodial charges and should discuss these differences with the Bleakley Advisor. Custodial Transaction-Based Charges: Schwab, Pershing and Fidelity offer custodial transaction-based pricing. The custodial transaction-based charges are billed by and paid to the custodian, on trade date, when a transaction is executed through the custodian and is based on the specific security or investment involved in the transaction. Custodial transaction-based charges are deducted from Bleakley’s wrap fee or, as applicable, deducted from the client’s non-wrap fee account. The custodial transaction-based charges cover various transaction costs, such as mutual fund fees, brokerage commissions and mark-ups/mark-downs for fixed income securities. Custodial Account and Other Charges: Each of the custodians utilized by Bleakley have miscellaneous account and other charges that are borne solely by the client and are deducted from the client’s wrap fee account. These custodial account and other service charges are billed by and paid to the custodian, based upon the specific custodial account or service, including, but not limited to, wire fees, transfer fees, margin interest, account activity fees, and any fee associated with maintaining a retirement account charged by the custodian of the qualified account. Custodians may waive custodian account and other service charges based on a level of assets maintained in the account, and the asset level or other conditions for a fee waiver may be higher or lower than those required by other custodians. Furthermore, a Bleakley Advisor, at the Advisor’s sole discretion, may pay any custodial account and other charge. Proprietary Investment Strategies Fees: As is the case with allocations to third-party investment management strategies, Bleakley’s wrap fee is separate and apart from fees related to any allocations to a Bleakley proprietary investment strategy (as described in Item 6). The investment management fees (asset-based) charged on Global Macro, Target Income, and Benestar range from 0.015% to 0.075% (15bps to 75bps), depending on the strategy and as established by Bleakley (the firm). The Bleakley UMA fee is a weighted average sum (total) of the fees charged for each strategist model. Bleakley does not charge an investment management fee for BMAP, BFMP, or the UMA Bleakley does not charge an investment management fee for BMAP or BFMP. Bleakley’s written advisory agreement, requiring the client’s affirmative consent prior to allocating client assets to any of Bleakley’s proprietary investment strategies, outlines the specific investment management fees that the client will incur when participating in any Bleakley proprietary investment strategy. Fee Calculation: Bleakley’s wrap fee is billed quarterly in advance. The valuation of the account, upon which Bleakley’s wrap fee is calculated, is based on the values as assessed by the custodian on the last business day of the calendar quarter (e.g., December 31, March 31, June 30, and September 30) and collected in the following month (e.g., January, April, July, and October). Note: At LPL, a Bleakley Advisor may, at the Advisor’s sole discretion, choose a different billing cycle (e.g., February, May, August, November or March, June, September, December); however, Bleakley’s investment advisory fee will still be calculated using the last valuation date in the 3-month period and billed in advance. The annual wrap fee is not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client. Bleakley calculates asset-based fees on assets placed under its management, including cash, cash equivalents and/or money market funds. Depending on the client’s investment objective and/or strategy, these cash balances could be relatively high and represent a material portion of the overall account. Clients should understand that the asset-based fees charged on these balances may exceed the returns provided by cash, cash equivalents or money market funds, especially in low interest rate environments. Clients should discuss the use of cash, cash equivalents and/or money market funds with the Advisor. Fee Payment: Generally, clients elect to have Bleakley’s wrap fee deducted from the client’s custodial account(s). Both Bleakley’s written advisory agreement and the custodial agreement(s) authorize the custodian(s) to debit the account(s) for the amount of Bleakley’s wrap fee and to directly remit that fee to Bleakley. Fee and Cost Differentials: As indicated above, Bleakley prices its services based upon various objective and subjective factors. As a result, Bleakley’s clients will pay diverse investment advisory fees based, among other things, upon the complexity of the engagement, and the level and scope of the overall investment advisory and/or consulting services to be rendered by the Bleakley Advisor. Additionally, clients will pay diverse custodial asset-based charge or custodial transaction-based charges, custodial account and service charges, and other investment-specific costs. For example, as previously described, Bleakley participates in several custodian-sponsored programs and services, third-party investment manager programs and TAMPs which charge varying levels of program fees and additional costs. As a result of these factors, the services to be provided by Bleakley and investments recommended to any particular client could be available from other advisors at lower fees or costs. All clients and prospective clients should be guided accordingly. Termination of Advisory Relationship: The written agreement, between Bleakley and the client, will continue in effect until terminated by either party by written notice in accordance with the terms and conditions of the written agreement. Following the receipt of a notice of termination, Bleakley will refund the portion of the advanced wrap fee paid based upon the number of days remaining in the billing period. Held-Away Assets: As further described in Item 6, Bleakley may charge a fee on the client’s held- away assets or separately provide the client with a written invoice. Based on a client’s instruction, this fee could be deducted from another account that the Bleakley Advisor manages for the client (held at one of Bleakley’s custodians) or paid directly by the client to Bleakley. The specific fee schedule is established in the Bleakley written advisory agreement. Additionally, if a client elects to engage Bleakley’s discretionary, investment advisory services for held-away assets, the cost of the third-party intermediary’s order management system and Bleakley’s associated administrative cost, both included in Bleakley’s advisory fee, are outlined in the client’s investment advisory agreement.