A. Description of Firm Adirondack Retirement Specialists (“Adirondack” or the “Firm”) is a Queensbury, New York- based investment management firm founded in 1997. As further detailed in Item 4.B., below, Adirondack offers services covering the areas of financial planning, portfolio construction and investment management. The Firm typically provides its services to individuals and high net worth individuals. The Firm is registered with the United States Securities and Exchange Commission as an investment adviser and organized under the laws of New York as a corporation. Adirondack is owned by Sean Berger and Adam Mark. Sean Berger serves as the Firm’s President, Treasurer, and Chief Compliance Officer. Adam Mark serves as Vice President and Secretary. For information on Mr. Berger’s qualifications and business background, please refer to his Form ADV Part 2B Brochure Supplement. B. Types of Advisory Services Offered Adirondack provides two types of advisory services: Financial Planning Services and Investment Management Services, both of which are more fully described below. 1. Financial Planning Services When discussed and mutually agreed upon by Adirondack and the client, Adirondack will provide Financial Planning Services regarding the management of the client’s financial resources, based upon an analysis of the individual client’s needs. The services range from comprehensive financial planning to more focused consultations, depending on the needs of each client. Generally, Adirondack first conducts a complimentary initial consultation during which pertinent information about the client’s financial circumstances and objectives is collected. For more comprehensive services, the Firm reviews and analyzes the information provided by the client and then typically offers a written financial plan containing recommendations designed with the intention of achieving the client’s stated financial goals and objectives. Financial plans are based on the client’s financial situation at the time the plan is presented and are based on the information disclosed by the client to Adirondack. Clients are advised that certain assumptions are made with respect to interest and inflation rates, use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. Adirondack cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As the client’s financial situation, goals, objectives, or needs change, the clients are strongly urged to promptly notify the Firm. For more information on the risks associated with investing, please refer to Item 8, below. Please Note. Adirondack believes that it is important for the client to address financial planning issues on an ongoing basis. Adirondack’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with the Firm. Please Also Note: Adirondack does not serve as an attorney, or accountant, and no portion of our services should be construed as same. Accordingly, Adirondack does not prepare legal documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys, accountants, etc.). The client is not under any obligation to engage any such professional(s). The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Adirondack and/or its representatives. If the client engages any professional (i.e., attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the engaged professional shall remain exclusively responsible for resolving any such dispute with the client. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not the Firm, shall be responsible for the quality and competency of the services provided. Adirondack does not receive compensation in relation to, or any portion of the professional fee that clients pay to, third parties to whom they have been referred. For Financial Planning Services, clients are free at all times to accept or reject any or all recommendations made by the Firm and clients retain the authority and discretion on whether to implement Adirondack’s recommendations. If the client decides to follow the recommendations, the client has the option, but is under no obligation, to request that Adirondack implement such recommendations through the Firm’s Investment Management Services. Should a client request Adirondack to implement such recommendations, the client will receive the services outlined in products, including annuities, when the client and Mr. Berger believe it to be in the client’s best interest. Rationales for such purchases typically include, among other things, desire by the client to have an income or death benefit guarantee, ability to pay for such guarantees associated with the product, tax deferral on non-qualified funds, and/or contributions to existing annuities which may receive a higher fixed rate of return. Insurance products are sold by Mr. Berger in his separate capacity as an independent insurance agent for carriers not affiliated with the Adirondack.1 If Mr. Berger implements insurance transactions in this separate capacity, he earns a sales commission but does not also charge investment management fees on money added to those annuities. This could present a conflict of interest since Mr. Berger is incentivized and earns insurance commission(s) for implementing insurance product recommendations made as part of the Firm’s Financial Planning Services. This conflict is mitigated by Mr. Berger zealously attempting to always act in the best interest of his clients. Please see Items 5, 10 and 14 below for additional information concerning such conflicts. Mr. Berger, in his capacity as a registered representative of American Portfolios Financial Services, Inc. (“APFS”), offers securities and non-advisory services to Adirondack clients. APFS is an SEC registered broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”). Accordingly, if a client chooses to open an account with APFS outside of the assets managed by Adirondack, then Mr. Berger customarily receives commissions and other concessions because of his relationship with APFS. Clients should be aware that this represents a conflict of interest. Clients are under no obligation to transact any business through APFS or Adirondack and other advisers or broker-dealers may offer similar services, with costs that are higher or lower than those obtainable from Adirondack or APFS. Please note that neither Mr. Berger nor Adirondack charge both commissions and advisory fees on the same account. Accordingly, some accounts are designated as “commission accounts” where Mr. Berger receives commissions as compensation on a given account or advisory fees based on a percentage of assets under management, but not both on the same account. Please refer to Item 5 1 In most cases, insurance sales occurred with legacy Adirondack clients (i.e., clients of the firm prior to becoming a registered investment adviser). below for important detailed information on fees and compensation. 2. Investment Management Services Adirondack provides clients with ongoing Investment Management Services, which may be performed on either a discretionary or non-discretionary basis. The Firm’s diversified portfolios typically consist of equities, fixed income and/or cash management instruments, including mutual funds, stocks, ETFs, bonds and other financial products. In addition, when appropriate, Adirondack can use certain option strategies to mitigate market risks. Adirondack customizes clients’ portfolios according to their individual risk tolerance, time horizon and specific goals. Generally, Adirondack primarily uses three investment strategies, which are customized to each individual to meet his/her/their objectives. This includes moderate conservative, moderate and moderate aggressive. Each client’s portfolio is managed on a “separately managed account” basis. Please note that at the onset of the engagement, as monies comes in, Adirondack allocates funds dependent upon market conditions and other factors, which may include dollar and value cost averaging. Adirondack invests client assets based on tactical allocation, taking into consideration the client’s unique needs and circumstances. Prior to engaging Adirondack to provide Investment Management Services, the client is required to enter into an Investment Advisory Agreement with the Firm setting forth the terms and conditions of the engagement, as well as describing the specific scope of the services to be provided, and the fee that is due from the client. To commence the investment advisory process, Adirondack will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, Adirondack provides ongoing supervision of the account(s). While clients can place certain restrictions on their accounts, such as restricting the Firm from purchasing or selling a specific security, Adirondack does not allow clients to place restrictions on the types of securities, industries or sectors that may be included as part of the client’s account. Note that cash positions can be a tactical asset, and there are times when Adirondack recommends that a client go to a money market fund (cash) for some or all of the account for tactical reasons. Clients are charged Adirondack’s customary asset under management fees pursuant to the terms of the Investment Advisory Agreement regardless of what type of positions are held in the account—including cash and cash equivalents. a. Gold Medal Services For clients

that generally have $500,000 or above within their household2 Investment Management account(s) for which a management fee is assessed will receive, in addition to Adirondack’s Investment Management Services, our complementary “Gold Medal Services.” These services include, but are not limited to, a comprehensive review of investments, tax reduction planning, retirement income and distribution planning, family wealth planning and protection planning. As a “Gold Medal Services” client, you will receive the option to have more frequent meetings with the Firm’s President as well as more frequent reviews and rebalancing of your portfolio(s) than those clients who are not classified as a “Gold Member 2 Adirondack defines a “household” as a legally married couple (either husband and wife or domestic partners) and children under the age of majority, whereby the parents are holding a minor’s assets for his or her benefit until he or she reaches the age of majority, who all reside at the same residential address. Services” client. b. 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 Adirondack recommends that a client roll over their retirement plan assets into an account to be managed by Adirondack, such a recommendation creates a conflict of interest if Adirondack will earn new (or increase its current) compensation as a result of the rollover. Whether Adirondack provides a recommendation as to whether a client should engage in a rollover or not, Adirondack 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 Adirondack. Adirondack’s Chief Compliance Officer, Sean Berger, 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. C. Wrap-Fee Programs Adirondack does not provide its services to any wrap fee program, as that term is defined the instructions to Form ADV Part 2. D. General Information About Adirondack’s Advisory Services As indicated above, advisory services provided by Adirondack are customizable based upon the individual needs, objectives, and other financial goals of the client. Early in the relationship, Adirondack will typically memorialize each client’s investment objectives, risk tolerance, time horizons and other important information, including any investment guidelines, in a client profile or similar document. This information, together with any other information relating to the client’s overall financial circumstances, will be used by the Firm to determine the most appropriate asset allocation and investment strategy to best meet the client’s financial goals. Adirondack will not assume any responsibility for the accuracy of the information provided by the client. The Firm is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying the Firm in writing of any material changes to the client’s financial situation, investment objectives, time horizon, tax status, risk tolerance or other material information that the Firm may have relied upon in rendering its services. If a client notifies the Firm of such changes, Adirondack will review the changes and may recommend revisions to the client’s financial plan and/or portfolio. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Adirondack generally recommends that Charles Schwab and Co., Inc. (“Schwab”) or TD Ameritrade serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Schwab and TD Ameritrade charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab and TD Ameritrade, generally (with the potential exception for orders) do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Schwab and/or TD Ameritrade will not change their transaction fee pricing in the future. Please Also Note: TD Ameritrade and Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. The above fees/charges are in addition to Adirondack’s investment advisory fee at Item 5 below. Adirondack does not receive any portion of these fees/charges. Cash Positions. Adirondack continues to treat cash as an asset class. As such, unless determined to the contrary by the Firm, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Adirondack’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Adirondack may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Adirondack’s advisory fee could exceed the interest paid by the client’s money market fund Use of Mutual and Exchange Traded Funds: Adirondack utilizes mutual funds and can use exchange traded funds for its client portfolios. In addition to Adirondack’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Non-Discretionary Service Limitations. Clients that determine to engage Adirondack on a non-discretionary investment advisory basis must be willing to accept that Adirondack cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Adirondack would like to make a transaction for a client’s account, and client is unavailable, Adirondack will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Portfolio Activity. Adirondack has a fiduciary duty to provide services consistent with the client’s best interest. Adirondack will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Adirondack determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Client Obligations. In performing our services, Adirondack 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, it remains each client’s responsibility to promptly notify Adirondack if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. 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 Adirondack) will be profitable or equal any specific performance level(s). Disclosure Statement. A copy of the Adirondack’s written Privacy Notice, Disclosure Brochure as set forth on Part 2 of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning Agreement. Any client who has not received a copy of Adirondack’s written Brochure at least 48 hours prior to executing the Investment Advisory Agreement and/or Financial Planning and Consulting Agreement shall have five business days subsequent to executing the agreement to terminate the Adirondack’s services without penalty. E. Amount of Client Assets Managed As of December 31, 2022, the following represents the amount of client assets under management by Adirondack on a discretionary and non-discretionary basis: Type of Account Assets Under Management ("AUM") Discretionary $213,495,092 Non-Discretionary $3,987,426 Total: $217,482,518