The Patriot Financial Group Insurance Agency, LLC d/b/a The Patriot Financial Group (herein “The Patriot Financial Group” or the “Advisor”) is registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Patriot Financial Group is organized as a limited liability company (“LLC”) under the laws of the Commonwealth of Massachusetts. The Patriot Financial Group became an LLC in Massachusetts in April 2004 and in September 2014, The Patriot Financial Group became a registered investment advisor with the SEC in order to achieve a greater degree of independence and operational efficiency. The Patriot Financial Group is owned and operated by David M. O’Donnell (President), Michael P. Tashjian (Chief Executive Officer) and Jon Loranger (Chief Compliance Officer). The Patriot Financial Group offers services through our Advisory Persons. Advisory Persons may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials and/or Client statements. The Client should understand that the businesses are legal entities of the Advisory Person and not of The Patriot Financial Group. The Patriot Financial Group conducts advisory business under the following additional business names (d/b/a names): The Patriot Financial Group Provo Wealth Management Group | Joffrey Smith Financial Group | Riverside Wealth Management Summit Star Advisory | Patriot Retirement Plan Partners | Rollover Advisory Services Rule Financial Services | Hayden Wealth Management | Riverside Retirement Advisors, LLC Unified Legacy Advisors | Galli Financial Group | Waypoint Wealth Management | Childs Financial Services McGrath Advisors Inc | Atlantic Wealth Management | B&D Advisors | JPS Financial | Sterling Endeavor Wealth Management Ivy Wealth Management, Inc | Alder Tree Financial | Good Habits Financial | Ivy Wealth Advisors | Ivy Retirement Solutions Flex Financial Planning | Comprehensive Wealth Management The Patriot Financial Group will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. The Patriot Financial Group evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. The Patriot Financial Group may recommend, on occasion, redistributing investment allocations to diversify the portfolio. The Patriot Financial Group may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. The Patriot Financial Group may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will The Patriot Financial Group accept or maintain physical custody of a Client’s securities. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. For additional information, please see Item 12 – Brokerage Practices and Item 15 – Custody. Use of Independent Managers - The Patriot Financial Group may recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent Managers”), which are available through the recommended Custodians. The Client may be required to enter into a separate agreement with the Independent Manager[s]. The Patriot Financial Group serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. The Patriot Financial Group will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. The Patriot Financial Group will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Form ADV Part 2A (or a brochure that makes the appropriate disclosures) of those parties. The Patriot Financial Group does not receive any compensation from these Independent Managers or Investment Platforms, other than The Patriot Financial Group’s investment advisory fee, as described in Item 5. Financial Planning Services As part of our financial planning services, The Patriot Financial Group may provide personal financial planning tailored to the individual needs of the Client. These services may include, as selected by the Client on the financial planning agreement, information and recommendations regarding tax planning, investment planning, retirement planning, estate needs, business needs, education planning, life and disability insurance needs, long -term care needs and cash flow/budget planning. The services take into account information collected from the Client such as financial status, investment objectives and tax status, among other data. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Hourly Consulting Services The Patriot Financial Group, through its Advisory Persons, may provide consulting services on an hourly basis. These services may include, as selected by the Client in the consulting agreement, advice regarding tax planning, investment planning, retirement planning, estate planning, cash flow/budget planning, business planning, education planning, insurance needs and personal financial planning. The services take into account information collected from the Client such as financial status, investment objectives and tax status, among other data. The Advisory Persons may or may not deliver to the Client a written analysis or report as part of the services. The Advisory Persons tailor the hourly consulting services to the individual needs of the Client based on the investment objective, selected by the Client. The engagement terminates upon final consultation with the Client. Fees for such services are negotiable and detailed in the Client agreement. Retirement Plan Advisory Services Advisory Persons of The Patriot Financial Group may assist Clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or advisory services. Investment advisor representatives may perform one or more of the following services, as selected by the Client in the Client agreement:
• assist the Plan in preparation or review of an investment policy statement (“IPS”) for the plan based upon consultation with Client;
• on a discretionary basis select the designated diversified investment options from which plan participants may choose, preparation and maintenance of an investment policy statement (“IPS”), provide ongoing quarterly investment monitoring, using Firm approved System and Tools;
• recommend for consideration and selection by Client, specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan. Investment Advisor Representative will recommend, for consideration and selection by Client, investment replacements if an existing investment is determined by the Client to no longer be suitable as an investment option. Investment Advisor Representative will perform ongoing quarterly monitoring of investment options in relation to the criteria provided by the Client to the Investment Advisor Representative using a Firm approved System and Tools;
• perform ongoing quarterly monitoring of investment options in relation to the criteria provided by the Client to the Investment Advisor Representative using a Firm approved System and Tools;
• assist Client in identifying an investment product or model portfolio in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA (for Plans subject to ERISA);
• recommend, for consideration and approval by Client, (i) asset allocation target-date or risk-based model portfolios for the Plan to make available to Plan participants, and (ii) funds from the line-up of investment options chosen by the Client to include in such model portfolios;
• prepare periodic reports (no less than annually) reviewing the performance of all Plan investment options, as well as comparing the performance thereof to benchmarks with Client. The information used to generate the reports will be derived directly from information such as statements provided by Client, investment providers and/or third parties;
• assist the Plan by acting as a liaison between the Plan and service providers, product sponsors and/or vendors. In such cases, Investment Advisor Representative shall act only in accordance with instructions from the Client on investment or Plan administration matters and shall not exercise judgement or discretion;
• provide education, training, and/or guidance, for the members of the Plan Committee with regard to plan features, retirement readiness matters, or duties and responsibilities of the Committee, including education with respect to fiduciary responsibilities;
• assist Client in enrolling Plan participants in the Plan, including conducting

an agreed upon number of enrollment meetings. As part of such meetings, Investment Advisor Representative will provide participants with information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact or preretirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan;
• assist with participant education, which may include preparation of education materials and/or conducting investment education seminars and meetings for Plan participants. Such meetings, may be on a group or individual basis, and may include information about the investment options under the Plan (e.g., investment objectives, risk/return characteristics, and historical performance), investment concepts (e.g., diversification, asset classes, and risk and return), and how to determine investment time horizons and assess risk tolerance. Such meetings shall not include specific investment advice about investment options under the Plan as being appropriate for a particular participant, but may include use of educational investment models;
• assist (periodically as appropriate according to industry standards) with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support;
• periodically provide Client with comparisons of Plan data (e.g., regarding fees, services, participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans; and
• assist Client in identifying the fees and other costs borne by the Plan for, as specified by Client, investment management, recordkeeping, participant education, participant communication and/or other services provided with respect to the Plan. If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the Plan, Advisory Persons do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan may invest the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or may obtain participant loans, Advisory Persons do not provide any individualized advice or recommendations to the participants regarding these decisions. Furthermore, Advisory Persons do not provide individualized investment advice to Plan participants regarding their Plan assets. We may agree to act as an “investment manager” to the Plan as defined under ERISA Section 3(38) with respect to any asset allocation models that are managed by the firm on a discretionary basis and included among the investment alternatives from which a participant may choose in managing his/her individual retirement account. Limitations of Financial Planning and Non-Investment Consulting/Implementation - As indicated above, to the extent requested by a Client, the Advisor may provide financial planning and related consulting services. Neither the Advisor nor its IARs assist Clients with the implementation of any financial plan, unless they have agreed to do so in writing. The Advisor does not monitor a Client’s financial plan, and it is the Client’s responsibility to revisit the financial plan with their IAR, if desired. The Advisor may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. The Advisor does not serve as an attorney or accountant, and no portion of its services should be construed as legal or accounting services. Accordingly, the Advisor does not prepare estate planning documents or tax returns. To the extent requested by a Client, the Advisor may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). 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 the Advisor and/or its representatives. If the Client engages any recommended unaffiliated 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 licensed professional (i.e. attorney, accountant, insurance agent, etc.), and not the Advisor, shall be responsible for the quality and competency of the services provided. Portfolio Activity - The Advisor has a fiduciary duty to provide services consistent with the Client’s best interest. As part of its investment advisory services, the Advisor 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, 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 the Advisor determines that changes to a Client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Client Obligations - In performing its services, the Advisor 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 their responsibility to promptly notify the Advisor if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Advisor’s previous recommendations and/or services. Retirement Plan Rollovers – No Obligation / 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 the Advisor recommends that a Client roll over their retirement plan assets into an account to be managed by the Advisor, such a recommendation creates a conflict of interest if the Advisor will increase its advisory fee as a result of the rollover. To the extent that Advisor recommends that Clients roll over assets from their retirement plan to an IRA managed by Advisor, then Advisor represents that it and its investment adviser representatives are fiduciaries under the Employment Retirement Income Security Act of 1974 (“ERISA”), or the Internal Revenue Code, or both. No Client is under any obligation to roll over retirement plan assets to an account managed by Advisor. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG”). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by the Advisor), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful Cash Positions. Advisor continues to treat cash as an asset class. As such, unless determined to the contrary by Advisor, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Advisor’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), Advisor 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, Advisor’s advisory fee could exceed the interest paid by the client’s money market fund. Account Aggregation Reporting Services. Advisor uses account aggregation software, which can incorporate client investment assets that are not part of the assets that Advisor manages (the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or their other advisors that maintain trading authority, and not Advisor, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, in writing, Advisor does not provide investment management, monitoring or implementation services for the Excluded Assets. The client can engage Advisor to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Advisor and the client. Wrap Fee Program The Patriot Financial Group may include securities transaction fees together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors The Patriot Financial Group Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. Assets Under Management As of December 31, 2023, the firm has managed $2,119,373,755 in discretionary assets under management and $18,771 in non-discretionary assets under management. Clients may request more current information at any time by contacting the Advisor.