Firm Description CLEAR POINT ADVISORS INC. (formerly known as Steven Brill Advisors, Inc.) was founded in 1998. Barry Dampf and Robert Levine joined CLEAR POINT ADVISORS INC. during 2009, having formerly been principals of the Registered Investment Advisor firm, Spielberger, Dampf, Brill & Levine, LLC. CLEAR POINT ADVISORS INC. provides personalized investment management services to individuals, pension and profit sharing plans, trusts and estates, charitable organizations and small businesses. Investment advice is provided after consultation with each client and includes the determination of investment goals and objectives, including a review of the client’s appetite and tolerance for risk, cash flow needs and income tax considerations. After consultation, an investment allocation is developed and tailored for each client’s situation and is reflected by the Target Allocation chart that is included at the beginning of each client’s quarterly investment summary report. Personal Financial Planning advice and analysis may be provided as an additional service to the investment management clients of CLEAR POINT ADVISORS INC, if requested by the client through a separate written engagement. (Absent a written engagement letter outlining areas of financial advice and analysis, CLEAR POINT ADVISORS INC and its officers should not be construed as providing comprehensive financial advice to its investment management clients.) Areas of planning may include retirement needs analysis (often conducted through “Monte Carlo” simulation); education funding, estate planning, insurance analysis, employment stock option strategies, and cash flow budgeting. CLEAR POINT ADVISORS INC. is a fee-only investment management firm and financial advisory firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. CLEAR POINT ADVISORS INC. or its advisors do not receive commissions through the sale of securities. CLEAR POINT ADVISORS INC. does not act as a custodian of client assets. The client always maintains asset control, since assets are held by an independent third party custodian. CLEAR POINT ADVISORS INC. places trades for clients under a limited power of attorney with the third party custodian. CLEAR POINT ADVISORS INC. may accept written authorization from clients to effect transfers of funds or securities to third parties, typically to another family member, through standing letters of authorization. Periodic reviews are conducted through in-person, telephone or zoom conferences with each client. Such reviews are conducted to provide an updated assessment of the progress to date in meeting the client’s investment goals and to determine any specific course of action that needs to be taken. More frequent reviews occur but are not necessarily communicated to the client unless significant immediate changes are recommended, in the judgment of the advisor. Other professionals (e.g., lawyers, accountants, insurance agents, bankers etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting, which may be by telephone or zoom call, is without of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. Principal Owners The stock ownership of CLEAR POINT ADVISORS INC. is indicated below. Over and above the stock ownership of the CLEAR POINT ADVISORS INC., each of the Advisors to the firm have a proprietary interest in the client accounts that they manage, by virtue of a separate agreement. There is a business disposition agreement between the firm principals designed to reflect their financial interests and to help ensure firm continuity over time. The firm is in the process of formalizing this agreement in written form. Steven C. Brill, JD (President) – more than 90% stockholder. Barry E. Dampf - (Managing Director) – less than 5% stockholder Robert Levine – (Managing Director) – less than 5% stockholder Types of Advisory Services CLEAR POINT ADVISORS INC. provides “investment supervisory services,” also known as asset management services for its clients. CLEAR POINT ADVISORS INC. manages investment advisory accounts generally on a discretionary basis. Accounts are discretionary, unless trading authority is not granted to the advisor on the account application. CLEAR POINT ADVISORS INC. limits the discretionary basis by not holding the power for itself or its employees to withdraw funds and/or securities from client accounts. Accounts can be maintained on a non- discretionary basis with CLEAR POINT ADVISORS INC. by an indication on the new account application between the client, the custodian and the Advisor. From time to time, CLEAR POINT ADVISORS INC. furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and trust services and estate planning and insurance. Clients generally do not receive such services unless requested from CLEAR POINT ADVISORS INC. A separate fee may be imposed for the rendering of such services by CLEAR POINT ADVISORS INC. relies upon research in executing client portfolios. Research sources include online sources and websites, financial newspapers, magazines and subscriptions, materials and presentations prepared by other firms (including research from JP Morgan, PIMCO, Capital Group, Blackrock, Blackstone, First Trust and Vanguard,) investment rating services (including Morningstar,) and annual reports and prospectuses filed with the Securities and Exchange Commission. CLEAR POINT ADVISORS INC. also conducts its own screening and research on many of the investment vehicles included in client portfolios designed to assess relative risk-adjusted performance. CLEAR POINT ADVISORS INC. or its principal Officers and employees typically invest in securities that it also recommends or acquires for its clients’ portfolios. There is no conflict of interest as the securities are widely-held and publicly traded. CLEAR POINT ADVISORS INC. internal policies prohibit its advisors from purchasing or selling securities in their own accounts on the same day as in that advisor’s clients’ accounts, at a superior price. (Trades that are initiated directly by the client without advisor assistance are excepted from this policy.) As of December 31, 2023, CLEAR POINT ADVISORS INC. manages $216,404,655 in discretionary assets for 148 client relationships. Tailored Relationships and Reporting The mix of assets designed to help achieve the goals and objectives for each client are reflected in the asset allocation pie chart maintained under our Portfolio Management and reporting system. Quarterly investment reports are prepared and distributed by CLEAR POINT ADVISORS INC. during the month following the close of each calendar quarter. The Quarterly report reflects both the Target Allocation and the Current Allocation for each client’s overall portfolio and any variation. The quarterly report also reflects each client’s current investment positions, portfolio withdrawals and additions, and portfolio and individual security performance. The reports also include historic annual investment performance, generally for the clients’ consolidated investment holdings under CLEAR POINT ADVISORS INC.’s management, typically from the inception of the relationship. The quarterly reports can assist clients in evaluating their progress towards meeting their financial objectives. Clients may impose restrictions on investing in certain securities or types of securities in their portfolio. In addition, clients receive monthly holding and transaction activity statements directly from the investment custodian. Such reports can be received by the client either in printed form or via electronic transmission, at the client’s option. The delivery of such statements cannot be suppressed by the Advisor, which helps ensure the security of the accounts. The custodian may not provide a statement for a month in which there is no investment activity in the account. Portfolio Investments In making investments for its clients’ portfolios, CLEAR POINT ADVISORS INC. may employ the use of exchange traded funds (ETFs), exchange traded products (ETPs), real estate investment trusts (both private and public,) and individual securities, including bonds and stocks. Investments may also include purchases of certificates of deposit, government bonds and paper as well as municipal securities. Most of these investments provide daily liquidity to investors, though interval funds may sometimes be bought that typically offer limited quarterly liquidity. While not typically used, options on stocks may be used on occasion to help meet specific client objectives or at a client’s request. Funds that are selected may employ such investment options as part of their investment process. Individual stocks are generally not among the recommended investments for CLEAR POINT ADVISORS INC. client accounts, nor have “separately managed accounts (SMAs)” been provided through third party managers, other than mutual funds and exchange traded products. Participation in Initial public offerings (IPOs) are not currently available through CLEAR POINT ADVISORS INC. “Direct Indexing” SMAs are expected to be made available to select clients going forward. Stocks and bonds may be purchased, held or sold through a brokerage account when directed by the client or when appropriate, in the discretion of the advisor. The Investment Custodian does not currently impose a fee for stock trades or on the purchase or sale of exchange traded funds. The custodian imposes a $15 fee on the purchase or sale of most mutual funds. The custodian continues to charge a mark-up on bond trades. CLEAR POINT ADVISORS INC. is a “fee-only” advisor and, as such, does not receive compensation from fund companies or from the custodian or brokerage firms for any investment trades. Private Investment Funds. Clear Point may also provide investment advice regarding private investment funds. Clear Point, on a non-discretionary limited basis, may recommend that certain qualified clients consider

an investment in private investment funds, generally limited to real estate investment trusts- REITs, business development companies (BCAs), or Private Credit offerings. Clear Point’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Clear Point calculating its investment advisory fee. Clear Point’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. Clear Point shall calculate its fee based upon the latest value provided by the fund sponsor. Investment Management Agreement CLEAR POINT ADVISORS INC.’s capabilities and limitations in managing client portfolios are granted by its clients through execution of the account agreement of the investment custodian and under the provisions of its Investment Advisory Agreement. The custodian’s account agreement enumerates certain powers conferred to CLEAR POINT ADVISORS INC. by each client in managing their accounts at the custodian firm. These powers typically include the right of CLEAR POINT ADVISORS INC. to execute trades in the client account on a discretionary basis, the right to request that checks be sent by the custodian to the client at their address of record with the custodian, and the right to enable the custodian to pay quarterly invoices presented by CLEAR POINT ADVISORS INC. for portfolio management services. CLEAR POINT ADVISORS INC. requires all new clients to enter into an Investment Advisory Agreement. The Agreement supplements the terms and conditions that help define the Adviser’s role under the custodian’s new account application. The existing clients of CLEAR POINT ADVISORS INC. will also be requested to execute an Investment Advisory Agreement. The Agreement does not fundamentally alter the manner in which Clear Point manages its clients’ assets and it retains the existing fee schedule. CLEAR POINT ADVISORS INC.’s services are ongoing, but the length of service to the client is at the client’s discretion. The client or the investment manager may terminate CLEAR POINT ADVISORS INC.’s services by written notice to the other party. At termination, fees will be prorated for the final quarter. The portfolio value at the time of termination is used as the basis for the fee computation. CLEAR POINT ADVISORS INC. reserves the right to impose a prorated fee for assets removed from, or added to, a client’s account prior to the end of any quarter, in its sole discretion. Retirement Plan Consulting Clear Point Advisors Inc. provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Such consulting services generally consist of assisting employer plan sponsors in establishing, monitoring, and reviewing their company's participant-directed retirement plan. Areas of advising may include investment options, plan structure, and participant education, as the needs of the plan sponsor dictate. In providing services for retirement plan consulting, our firm does not provide participant investment advisory services unless a separate arrangement has been made with the plan trustee in writing. All retirement plan consulting services are provided in compliance with applicable state laws regulating retirement consulting services. This applies to retirement or other employee benefit plan accounts (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If participant accounts are part of a Plan, and our firm accepts appointments to provide services to such accounts, our firm acknowledges its requirement to adhere to a fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Clear Point Advisors Inc. Retirement Plan Consulting Agreement with respect to the provision of services described therein. Miscellaneous Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, CLEAR POINT ADVISORS INC. may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Neither CLEAR POINT Advisors, nor any of its representatives, serves as an attorney, accountant, or insurance agent, and no portion of CLEAR POINT ADVISORS INC.’s services should be construed as same. To the extent requested by a client, CLEAR POINT ADVISORS INC. may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.). This may include individuals who serve, or have served, as paid solicitors on behalf of CLEAR POINT ADVISORS INC. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from CLEAR POINT ADVISORS INC. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged unaffiliated licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.,) and not CLEAR POINT ADVISORS INC., shall be responsible for the quality and competency of the services provided. Please Note: It remains the client’s responsibility to promptly notify CLEAR POINT ADVISORS INC. if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising CLEAR POINT ADVISORS INC.’s previous recommendations. Retirement Rollovers-No Obligation/Conflict of Interest: Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Clear Point recommends that a client roll over their retirement plan assets into an account to be managed by Clear Point, such a recommendation creates a conflict of interest if Clear Point will earn new (or increase its current) compensation as a result of the rollover. If Clear Point provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Clear Point is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Clear Point, whether it is from an employer’s plan or an existing IRA. Clear Point’s Chief Compliance Officer, Steven Brill, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Account Aggregation/Excluded Assets: CLEAR POINT ADVISORS INC. may also provide the client with access to third-party software, which can aggregate all of the client’s investment assets, including those investment assets that are not part of the assets that we manage (the “Excluded Assets.”) The client and/or his/her/its other advisors that maintain trading authority, and not us, shall be exclusively responsible for the investment performance of the Excluded Assets. The client may engage CLEAR POINT ADVISORS INC. to manage the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between CLEAR POINT ADVISORS INC. and the client. Client Obligations. In performing its services, CLEAR POINT ADVISORS INC. shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify CLEAR POINT ADVISORS INC. if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising CLEAR POINT ADVISORS INC. previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by CLEAR POINT ADVISORS INC.) will be profitable or equal any specific performance level(s). Disclosure Statement. A copy of CLEAR POINT ADVISORS INC. written Brochure as set forth on Part 2A & 2B of Form ADV is provided to each client. For new client relationships, a copy of CLEAR POINT ADVISORS INC.’s written Brochure as set forth on Part 2A & 2B of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement.