SIA offers financial planning and investment management services. Prior to the rendering of any of the foregoing advisory services, clients are required to enter into one or more written agreements with SIA setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). SIA began operating as an independent registered investment adviser in October 2013. Since January 1, 2020, Samanjo, Inc. has been the Direct Owner of SIA. Marc R. Schechter is the indirect owner of SIA and owns 100% of Samanjo, Inc. As of December 31, 2023, SIA had $3,349,365,530 of total assets under management, $2,869,520,846 of which was managed on a discretionary basis and $ $479,844,684 was managed on a non-discretionary basis. While this brochure generally describes the business of SIA, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice subject to the Firm’s supervision or control. Financial Planning and Consulting Services SIA offers its clients a range of financial planning and consulting services, including:  Asset Allocation  Insurance Needs Analysis  Retirement Planning  Retirement Plan Analysis  Estate Planning  Charitable Giving Planning  Investment Consulting  Income Tax Planning While some of these services are available on a stand-alone basis, certain services may be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (as described below). In performing these services, SIA is not required to verify information received from the client or from the other professionals advising the client (e.g., attorneys, accountants, etc.). In addition to the above listed services, SIA recommends services offered by its Supervised Persons in their individual capacities as insurance agents or registered representatives of a third-party broker-dealer in order to implement its recommendations, which creates potential conflicts of interest for those individuals. (See Item 10, Other Financial Industry Activities and Affiliation for a further description of SIA’s conflicts of interest). Clients are advised that if they engage SIA to provide additional fee-based services, the client retains absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by SIA under a financial planning or consulting engagement or to engage the services of any such recommended professionals, including SIA itself. Investment Management and Wealth Management Services SIA manages client investment portfolios on a discretionary or non-discretionary basis. In addition, SIA offers clients wealth management services, which include the broad range of comprehensive financial planning and/or consulting services described above. SIA primarily allocates client assets among various independent investment managers (“Independent Managers”), mutual funds, interval funds, exchange-traded funds (“ETF”), and individual debt and equity securities in accordance with the investment objectives of its individual clients. In addition, SIA may also recommend that clients who, at a minimum, qualify as accredited investors (or the necessary accreditation specific to the investment) as defined by Rule 501 of Regulation D under the Securities Act of 1933, invest in privately placed securities, which may include debt, equity, or interests in pooled investment vehicles (e.g., hedge funds), including investments in private funds issued and managed by SIA’s affiliated SEC registered investment advisor, Schechter Private Capital, LLC (“SPC”). (See Item 10, Other Financial Industry Activities and Affiliations for a description of SIA’s conflicts of interests relating to SPC.) SIA tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. SIA consults with clients on an initial and ongoing basis, at least once annually, to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are asked to promptly notify SIA if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts, if SIA determines, that the restrictions or mandates will not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Certain clients of SIA may also work with other advisors/brokers and engage SIA to only manage or oversee a portion of their assets. In these situations, a holistic approach is limited and the management of the portfolio is typically focused on the specific assets that the client has hired SIA to manage. Clients may also engage SIA to advise on certain investments and/or plans that are not maintained at their primary custodian, such as variable and fixed life and annuity insurance contracts, assets held in employer sponsored retirement plans, and qualified tuition plans (i.e., 529 plans). In these situations, SIA directs or recommends the allocation of client assets among the various investment options available. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. Schechter Reporting Services SIA offers a consolidated reporting service primarily to high-net-worth individuals who are not currently an SIA advisory client. Through this service, SIA provides asset and other financial reporting services delivered through a client portal. SIA utilizes third-party reporting software for this service, which develops reports based on client needs and specifications. SIA charges clients a flat annual fee for this service, which is negotiable depending upon the size of the client account(s), size of non-custodial/outside accounts, and frequency of reporting provided by SIA. SIA also offers its consolidated reporting clients a fee discount should they choose to engage SIA for any additional fee-based services, as well. Any such discount will be negotiable on a client-by-client basis, depending on account size, complexity, type(s) of services, and amount of service provided at that time. Securities-Based Lending Program SIA and its Supervised Persons may assist clients in entering into a loan agreement establishing a line of credit offered through SIA’s primary custodian, Pershing LLC, depending upon the client’s investment needs and objectives. The ‘Pershing LoanAdvance Lending Program’ (“LoanAdvance”) enables SIA clients to obtain credit secured by their securities and other property held, carried, or maintained by the client in Pershing’s possession, also known as “pledging”. The client is responsible for independently evaluating whether the terms on which Pershing is willing to lend are acceptable. Clients’ assets that are custodied with firms other than Pershing will also generally have similar securities-based lending programs available to them, including Schwab and Fidelity. The fees related to a securities-based loan are separate from the advisory fees charged to a client’s advisory account. Clients should explore the details of the LoanAdvance program, and any other securities-based lending agreement, with their Advisor in order to determine whether the arrangement is appropriate to meet the client’s needs. Neither SIA nor its Supervised Persons receive any direct or indirect compensation or benefit for recommending clients to the LoanAdvance program. Use of Independent Managers SIA may select or recommend certain Independent Managers to manage a portion of its clients’ assets. The specific terms and conditions

under which a client engages an Independent Manager are set forth in a separate written agreement between the designated Independent Manager and either SIA or the client. In addition to this brochure, clients may also receive written disclosure documents of the Independent Managers engaged to manage their assets. SIA does not receive compensation from any such Independent Manager. SIA evaluates various information about the Independent Managers it chooses to manage client portfolios, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves, and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposure. SIA also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. On an ongoing basis, SIA monitors the performance of those accounts being managed by Independent Managers. SIA seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The following list is not all-inclusive but represents specific programs or offerings SIA utilizes. Callan Associates, LLC Callan Associates, LLC (Callan), a third-party federally registered investment adviser, is one of multiple third- parties SIA utilizes to select Independent Managers. Callan evaluates independent investment managers across multiple assets classes. Using qualitative and quantitative screens, Callan develops and provides SIA with a list of vetted and approved Independent Managers. In addition, Callan also negotiates lower investment minimums and fees with these Independent Managers for SIA clients. Finally, Callan provides ongoing due diligence on these managers to determine if they should remain on the approved list. SIA may select Independent Managers from this Callan approved list for use in client portfolios. SIA works with Callan using two different investment platforms. The first is the Callan Unified Managed Account (UMA) platform. The Callan UMA platform is an integrated investment platform in which a client’s assets can be invested in a single custodial account across multiple asset classes. On the UMA platform, Callan provides a list of approved independent managers (i.e., sub-advisors), whose portfolios are implemented by a Callan approved independent overlay manager, Managed Portfolio Advisors (MPA), a division of Natixis Global Asset Management (NGAM). After portfolio implementation, MPA is responsible for the ongoing trading, tax loss harvesting and portfolio rebalancing of clients’ accounts. There are different fee components on the UMA platform. These include SIA’s investment management fee, which is described in more detail under Item 5. Fees and Compensation, the fees for the various independent investment managers, the Callan fee, the MPA fee, and in some cases a custodial fee. A client’s specific fee associated with the program will be dependent on several factors, including assets under management, portfolio allocation, and the independent managers used to implement the portfolio. Client assets on the UMA platform are invested on a discretionary basis by MPA. SIA receives no compensation from any of the financial institutions associated with the UMA program and only collects its management fee. In addition to the UMA platform, SIA works with Callan through a separately managed account platform (SMA), in which client assets are invested in multiple accounts, each managed by an individual investment manager that is responsible for performing their own trading on the account. Callan provides SIA with a list of approved managers. The fees on this investment platform include the SIA fee, the fees paid to the independent investment managers and in some cases the custodian. SIA receives no compensation from any of the financial institutions associated with the SMA program and only collects its management fee. Schwab Managed Account Select Platform SIA may also use the Schwab Managed Account Select Platform. On this platform, Schwab performs the investment manager due diligence and provides SIA with a list of approved managers to use to implement client portfolios. On the Schwab platform, the typical manager minimum account size is $100,000. The fees on the Schwab Managed Account Select Platform include the SIA fee and the Schwab fee. The Schwab fee is an asset-based fee which incorporates the fee to Schwab, the independent managers, and the custodial fee if applicable. The assets of the Schwab Managed Account Select Platform are invested on a non-discretionary basis. The fees mentioned above are independent of each other and the client is responsible for all independent fees. SIA receives no compensation from any of the financial institutions associated with the Schwab Managed Account Select Platform and only collects its management fee. Alternative Investments In addition to traditional investment vehicles, SIA also invests client assets using alternative investments and structured notes. SIA considers a variety of third-party alternative investment platforms such as, for example, the Capital Integration Systems, LLC (CAIS) platform, but may also consider direct investments with private hedge funds, private equity or debt funds. SIA also considers other managers providing structured solutions. CAIS sources and selects new funds for its platform through a due diligence process conducted by Mercer Investment Consulting (Mercer). The process typically includes discussions among CAIS, prospect funds, their managers, Mercer and other relevant third parties experienced with the managers. Products that are appropriate and desirable for the platform are subject to internal committee reviews by CAIS and full, independent diligence review by Mercer in addition to the due diligence SIA completes. Product onboarding occurs only following the successful completion of these processes. Following onboarding, a regular dialogue and review is maintained with respect to each fund so long as it remains on the platform. The use of the CAIS platform enables SIA’s clients to have access to alternative investments at meaningfully lower dollar amounts, often starting at $100,000 minimum investments, than the funds usually require. The management fees and the carried interest vary at the fund level. Finally, there are alternative investment managers that SIA uses that are not on the CAIS platform that SIA independently analyzes. The fees on these funds also vary by fund. Investments made through CAIS are made through feeder funds created by CAIS to gain access to the underlying managers or facilitated by CAIS for investors to subscribe directly to the desired fund. CAIS assists with administration, subscription documents, ongoing maintenance, and custodial platform recognition. Although SIA believes that it has expertise in alternative investments, SIA also benefits from the additional due diligence and administrative support done by CAIS. SIA also uses and evaluates other third-party platforms in addition to CAIS, including iCapital. Mutual Funds and ETFs SIA also utilizes mutual funds, ETFs, and other traditional securities in managing client portfolios. SIA performs internal research and analysis when considering any such investments. In addition, SIA has relied upon Callan to screen certain mutual funds for SIA. In addition to using Callan approved mutual funds when implementing client portfolios, SIA will also look to use mutual funds from additional platforms or managers, and other index mutual funds and/or ETFs.