Bluestone® Financial Advisors, LLC (“Bluestone®, us, we, and ours”) is an investment advisor formed as a Limited Liability Company under the laws of the State of Maryland. Bluestone has been registered as an investment advisor since June 2008. Bluestone was formed for the purpose of providing investment and non-investment advisory services to entrepreneurs. Bluestone is owned by Andrew S. Cosgrove. We serve as personal CFO to entrepreneurs. Similar to a business CFO, our personal CFO work focuses on four key areas:
• Supporting the entrepreneur’s long-term financial strategy;
• Capital allocation;
• Risk management; and
• Reporting and financial organization. Advisory services include financial planning, consulting, and may include investment management. Advisory services are unique to each entrepreneur but generally include some combination of review, analysis, recommendations, and planning. Client deliverables capture information about each client’s circumstances, communicate recommendations, and facilitate planning and goal setting. Financial planning and consulting services do not involve the active management of client investment accounts, but instead are typically more comprehensive so as to focus on a client’s overall financial situation. Non-investment related advisory services are offered for cash management, business assets, real estate, personal insurance, estate and business succession planning, and health management. Our primary focus is on ensuring that planning and actions for each of these asset types is appropriate in the context of the other asset types that make up the client’s net worth. Services are offered on a fixed fee basis. This compensation model has been carefully chosen and is a very important part of the Bluestone’s approach. From the client’s perspective, we think it is the preferred approach for mitigation of conflicts of interest when delivering advisory services across a broad range of asset types. Description of Advisory Services Personal CFO services are offered in two different ways: (1) Project (“Financing Planning & Consulting”):
• Includes planning services but does not include investment management
• Services are provided over a short time period (typically 90-120 days)
• Client pays a one-time fixed fee (2) Retainer (“Financial Advisory”):
• Includes planning services and may include investment management
• Services continue for as long as the client elects (typically multi-year service period)
• Client pays a fixed fee each month We generally recommend that you engage us for the Project service prior to engaging us for the Retainer service. This allows you to evaluate us, and vice versa, over a relatively short period of time prior to entering into the Retainer service. While there is no time commitment required of you in engaging us under the Retainer service and you are free to terminate at any time, it is generally anticipated that services will be provided under the Retainer service over a time period that is substantially longer than for the Project service. Additional Information Regarding Advisory Services As part of our review of each asset type, we may make recommendations for resources and services provided by independent third parties, if, in our opinion, such resources may assist the entrepreneur in achieving their stated objectives. Resources may include accountants, attorneys, real estate professionals, consultants, private health advisory firms, etc. Under no circumstances do we receive compensation from any independent third-party resource or service. In performing advisory services, we are not required to verify any information received from you or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on such information. We may recommend that you use us and/or other professionals to implement recommendations provided by us. A conflict of interest exists whenever we recommend our own services. You are under no obligation to act upon any of the recommendations made by us or to engage the services of any recommended professional, including the services offered by us. You retain absolute discretion over all implementation decisions, and you are free to accept or reject any of our recommendations. Moreover, you are advised that it remains your responsibility to promptly notify us if there is ever any change in your financial situation or investment objectives. Investment Management Services for Securities Portfolios For clients electing the Retainer Service we may provide investment management services on a discretionary, non-discretionary, and advised basis. Each investment account is scheduled as a discretionary, non-discretionary, or advised account in your executed agreement with us. We perform research and due diligence consistent with our investment philosophy in order to identify suitable investments for your account. We seek to identify mutual funds, separate accounts, hedge funds and/or similar private investment vehicles with managers whose investment philosophy and process are consistent with our investment philosophy for a given objective. Primary objectives include:
• Reserve Assets – primary focus on liquidity and safety of principal
• Growth Assets – primary focus on growing purchasing power over time (5+ years)
• Aspirational Assets – higher risk assets characterized by potential for strong wealth creation Managers of the investment products identified and recommended by us will generally employ an investment process with a very strong focus on the valuation of businesses, securities, and other assets. They will tend to employ fundamental research in an attempt to identify assets they consider to be mispriced relative to the underlying “fair value” of the asset. Such managers may also require that certain parameters be met prior to committing capital to new investments, and to the extent these parameters are not met there may be extended periods of time in which the recommended managers will hold substantially more cash in their portfolios, relative to other managers. Discretionary Investment Management Services For any assets or accounts that are designated to be managed via the use of discretionary trading authority you authorize us to make changes in your account without your further approval. When providing discretionary investment management services, we primarily allocate your investment management assets among mutual funds in accordance with your investment objectives. Non-Discretionary Investment Management Services We may render

non-discretionary investment management services to you for any accounts or assets you so designate. For any assets or accounts that are designated to be managed via the use of non-discretionary trading authority, we will be required to contact you prior to implementing changes in your account. This means that for these assets and accounts, you will be contacted and required to accept or reject our investment recommendations including:
• The security being recommended
• The number of shares or units
• Whether to buy or sell Assets Under Advisement Services We may provide continuous and ongoing supervision for certain of your non-managed assets which will be identified and referred to as Assets Under Advisement in your executed agreement. For Assets Under Advisement, we will provide active monitoring and supervision and will provide you advice regarding buying, selling, reinvesting or holding securities, cash or other investments but will not have trading authority. You will have the sole responsibility for implementing any recommended transactions. Similar to our discretionary and non-discretionary investment management services, for Assets Under Advisement we will obtain information from you to determine your financial situation, investment objectives and risk tolerance. Assets Under Advisement are commonly assets or accounts for which we are not formally indicated on the custodial statement as the investment adviser of record on the account. You will receive an account statement from the qualified custodian of the Assets Under Advisement detailing transactions in the Account. You will be responsible for promptly notifying us of any changes to your financial situation or investment objectives. Assets Under Advisement Services are typically offered for (1) private (non-registered) investment funds, and/or (2) separately managed accounts, and/or (3) variable life/annuity products that you may own, and/or (4) your employer-sponsored retirement plans. Private (non-registered) investment fund assets are held at the custodian(s) designated by the manager of the fund. Separately managed account assets are held at the custodian(s) designated by the manager of the separate account. Variable life/annuity assets are maintained at the specific insurance company that issued the variable life/annuity product which is owned by you. Your employer-sponsored retirement plan assets are held at the custodian designated by the sponsor of your retirement plan. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs We do not participate in any wrap fee programs. Other Information about Investment Management Services We primarily construct each client’s portfolio using mutual funds, separate accounts, hedge funds and/or similar private investment vehicles. We may modify our investment approach to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. Account construction is generally customized to meet the individual needs of each client. We may agree to allow you to impose restrictions on the accounts managed on your behalf. You may make additions to and withdrawals from your account at any time. You may withdraw account assets on notice to us, subject to the usual and customary securities settlement procedures. However, you should note that we design our portfolios as long-term investments and asset withdrawals may impair the achievement of your investment objectives. Additions to your account may be in cash or securities provided that we reserve the right to liquidate any transferred securities or decline to provide advisory services to particular securities in your account. We may consult with you about the options and ramifications of transferring securities. However, you are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. You are advised to promptly notify us if there are ever any changes in your financial situation or investment objectives or if you wish to impose any reasonable restrictions upon our management services. Client Assets Managed by Bluestone The total amount of client assets managed by us as of December 31, 2023, was $146,446,558; $132,557,878 was managed on a discretionary basis and $13,888,680 was managed on a non- discretionary basis. The total amount of client assets advised by us as of December 31, 2023, was approximately $119,894,000.