A. General Description of Advisory Firm Polaris Wealth Advisory Group, LLC (referred to in this Brochure as the “Firm”, “Polaris,” “us,” “we,” or “our”) was formed on June 9, 2011, as Polaris Wealth Advisers, LLC and then later changed its name to Polaris Greystone Financial Group, LLC. On August 5, 2020, the Firm changed its name to Polaris Wealth Advisory Group, LLC. On May 26, 2022, the Firm became a wholly owned subsidiary of Adviser Investments, LLC (“Adviser”), an investment adviser registered with the SEC. Adviser is principally owned by certain investment vehicles advised by Summit Partners, L.P., an investment adviser registered with the SEC. Polaris’ principal place of business is in San Rafael, California. The Firm provides wealth management services to its clients (the “client,” “you,” or “your”). We offer wealth management services to individuals, pension plans, profit-sharing plans, trusts, estates, charitable organizations, businesses, unaffiliated investment advisers, and third-party asset management platforms (“TAMPs”). Services available to clients include discretionary and non-discretionary investment management, financial planning, tax strategies including return preparation and filing, risk management, and estate planning. Financial Planning We offer general financial planning and consultative services as an integral part of our management services described below. Financial planning will typically involve developing a plan to use a variety of advisory services to manage the client’s financial resources based upon an analysis of such client individual needs. Financial planning simplifies the client’s situation and helps determine financial alternatives by: (1) defining and narrowing such client’s objectives and investment options; (2) identifying the areas of greatest concern; (3) creating a unique picture of such client’s overall financial situation, and (4) by providing an effective way for us to address each client’s unique financial needs and objectives. We utilize in-depth personal meetings with clients, and their professional advisors if required, to determine the client’s investment goals and objectives. These services are rendered in accordance with personal circumstances as determined in these meetings, and will generally include the client’s current financial situation, age, family position, level of investment experience, risk tolerance, earning capacity, tax situation and goals and objectives. Our financial planning and consulting services include, but are not limited, to:
• General Financial Planning
• Educational Fund Planning
• Retirement Planning
• Estate Planning
• Corporate Retirement Planning
• Investment Planning
• Individual Tax Planning
• Risk Management
• Business Planning
• Business Succession Planning We may also use financial planning software that incorporates actual historical data for specific asset classification to determine a historical, statistical analysis of your current portfolio. Client interviews are utilized to gather information prior to any recommendation of advisory services. Once we review and analyze the information provided to us, we will deliver a written plan to the client, should the client desire one, that is designed to help the client achieve his or her stated financial goals and objectives. Financial plans are based on the client’s financial situation at the time we present the plan to the client, and on the financial information the client provides to us. The client must promptly notify us if his or her financial situation, goals, objectives, or needs change. The client is under no obligation to act on our financial planning recommendations. If requested, as part of our financial planning/consulting services, we will introduce the client to, or utilize, various third-party service providers. Complete and full disclosure of any relationship between Polaris and third parties, including any shared fee arrangement, will be provided to the client when recommending a third party. Advisory Services We offer specific recommendations regarding investing in Polaris’s strategies as well as general recommendations in such areas as clients’ overall investment mix, retirement planning, estate planning, education planning, and insurance planning. Polaris does not provide tax or legal advice or services. Our advisory services are based upon our clients’ stated objectives and risk tolerance. Clients are matched to a particular Polaris strategy or strategies. These include diversified exchange-traded fund (“ETF”) strategies and stock strategies. Certain clients will also have access to strategies of our affiliate, Adviser, and/or of other advisers, which can include ETFs, mutual funds, individual equities, and individual bonds. For our clients’ accounts utilizing such strategies, Adviser or the relevant other adviser acts as a sub-adviser, typically pursuant to a sub-advisory agreement between Adviser or such other adviser and Polaris, as discussed in Item 10. Such clients receive and review the sub-adviser’s Form ADV Part 2A for important information about the fees, expenses, risks, and conflicts of interest associated with the sub-adviser’s strategies and services. In addition to the strategies we manage, Polaris provides advisory services by allocating and reallocating assets in 529 plans, 401(k) plans, and variable annuity investments, and provides guidance regarding such allocations, consistent with the portfolio allocation chosen by the client. The investment choices available are limited by the specific offerings of each plan or product. Sub-Advisory Services From time to time, Polaris may enter into sub-advisory agreements with other registered investment advisers, including Adviser. Such sub-advisory agreements will normally be established so that Polaris can provide advisory services to the other adviser’s clients. Under these arrangements, Polaris will act as the sub-adviser. Polaris will offer the same selection of investment strategies to these other advisers as is offered to its own clients. The adviser will determine the suitability of Polaris’s strategies for its clients. Polaris will have full discretion to manage the adviser’s clients’ accounts. When such sub-advisory agreements are made, the sub-advisory arrangement will be disclosed by the adviser to its clients by delivery of the Form ADV Part 2A for the adviser and for Polaris. Investment Management as a 3(38) Fiduciary Manager for Qualified Plans We provide, on a discretionary basis, advisory services to qualified retirement plans which are subject to the Employee Retirement Income Security Act of 1974, as

amended (“ERISA”). As part of our services to qualified plans, we will act as a fiduciary of the plan under Section 3(21)(A)(ii) and as an investment manager under Section 3(38) of ERISA. As a 3(38) investment manager, the client gives us discretionary authority to manage the plan’s assets. This means the client shifts his or her fiduciary responsibility to us for the selection of the plan’s investments. For all qualified plan clients, we will review the plan’s investment objectives, risk tolerance and goals with the fiduciary or we will review and amend the plan’s existing investment policy statement (“IPS”). The review will incorporate considerations such as employee and participant demographics, nature of asset class categories, any limits or investment return objectives for the asset class categories set forth in the IPS including the designated investment alternatives. The client is able to place restrictions on the types of investments the plan invests assets in. Under our investment management agreement, we will have limited discretionary authority to manage the plan’s assets in accordance with the client’s investment objectives, risk tolerance and goals. We will select, monitor, remove, and replace the plan’s designated investment alternatives, including a qualified default investment alternative as defined in ERISA 404(c)(5) and DOL Regulation 2550.404c5 (the “Designated Investment Alternatives”) consistent with the IPS. The designated investment alternatives will comprise the plan’s core investment menu. As a 3(38) investment manager, we will retain full discretionary authority to make changes to the designated investment alternatives without prior consultation with the client. We continually monitor the performance of all investment options. If elected by the plan fiduciary, we may offer investment advice (“Advice Services”) to plan participants as an additional service under our agreement, subject to the terms and conditions set forth in the Participant Advice Supplement. Advice Services will be available to plan participants in two ways: (a) by telephone service and (b) in person. Our representatives will gather information concerning plan participant’s time horizon, risk tolerance, and investment goals. Our representatives will review the information provided and invest, on a discretionary basis, the participant’s account in accordance with his or her objectives. Advice Services are provided only to those participants who elect to meet with our representatives and accept our services. Investment Management to Accredited Investors Polaris provides discretionary advisory services to a flexible premium deferred variable annuity policy (the “Policy”) issued by Lombard International Life Assurance Company (“Lombard”). The Policy is intended for financially sophisticated investors who are “Accredited Investors” within the meaning of Rule 501 of Regulation D under the Securities Act of 1933, as amended. The Policy is not suitable for all persons since it may pursue an investment strategy that may include alternative investments (“Alternative Investments”) such as, without limitation, structured products (“Structured Products”), which may be highly illiquid. The Policy provides for the accumulation of capital on a tax-deferred basis for intermediate and long-term purposes (although there is no guarantee that the intended tax deferral will be obtained). In addition to the foregoing, we may offer and invest assets of certain qualified and high net worth clients directly in Alternative Investments. If we recommend to a client an investment in the Policy or recommend Alternative Investments to a client, we will provide such client with the private placement memorandum (the “PPM”) or additional information describing, in detail, the additional risk and expenses associated with the Policy or Alternative Investments, as the case may be. We strongly urge potential investors to read thoroughly the PPM including the surrender provisions and to consult with their own tax advisors with respect to the federal tax consequences associated with the Policy. Estate Planning Our firm offers Estate Planning services to our clients that consists of education on estate planning topics and the collection of general information necessary to complete a new estate plan or review a current estate plan. We also assist the client in gathering the required information needed to provide outside estate planning firms so that an estate plan can be created or updated. Any and all fees paid by the client for outside referred services will be paid to those service providers directly. Clients are not required to utilize any third-party products, services or referrals that we may recommend and can select the service provider of their choice. Tax Return Filing Services We offer tax return preparation and filing services through our wholly owned affiliate, Adviser Tax Solutions. Clients receiving tax return preparation and filing services generally pay a separate fee for these services, although other fee arrangements can be negotiated. Adviser Tax Solutions reserves the right to decline to prepare a particular client’s tax returns for any reason. Tax return preparation and filing fee rates are determined on a case-by-case basis depending on the complexity and estimated hours needed for completion. B. Availability of Tailored Services for Individual Clients The Firm will provide advice to client accounts based on each client’s specific wealth management and financial planning goals, investment objectives, and strategies. The Firm will also tailor its advisory services by adhering to the investment restrictions imposed by clients. The Firm’s authority is subject to conditions imposed by the client, examples of which include where: 1) the client restricts or prohibits transactions in securities of a specific industry, and/or 2) the client directs that transactions be effected through specific brokers and dealers. The latter restriction may be conditioned by the client on the broker or dealer being competitive as to price and execution for each transaction, or offering a specified level of commission discount or may be subject to varying degrees of restrictions such as an instruction to utilize the broker or dealer: a) whether or not competitive, and b) where the specified levels of commission discounts are less favorable than might otherwise be obtained by the Firm. C. Client Assets under Management As of December 31, 2022, the Firm had approximately $1,508,969,000 in regulatory assets under management, of which approximately $1,421,955,000 is managed on a discretionary basis and approximately $87,014,000 is managed on a non-discretionary basis.