CASTLEVIEW PARTNERS, LLC

Castleview Partners, LLC FORM ADV, PART 2A - Disclosure Brochure March 31, 2025 This Disclosure Brochure provides information about the qualifications and business practices of Castleview Partners, LLC (“Castleview”). If you have any questions about the content of this brochure, please contact the Advisor at (214) 710-1995, or by email at: compliance@castleviewpartners.com The information in this Disclosure Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Castleview is also available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. Castleview’s CRD number is: 281410. 8111 Preston Road Suite 500 Dallas, TX 75225 (214) 710-1995 (972) 361-1001 compliance@castleviewpartners.com Registration does not imply a certain level of skill or training. Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 1  ITEM 2: MATERIAL CHANGES Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Adviser’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Castleview. Castleview believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Castleview encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Adviser. Castleview does not have any material changes to disclose with this filing. Future Changes: From time to time, the Adviser may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes will be provided to you annually and if a material change occurs. You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Adviser’s firm name or CRD# 281410. You may also request a copy of this Disclosure Brochure at any time by contacting the Adviser at (214) 710- 1995 or by email at compliance@castleviewpartners.com Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 2  ITEM 3: TABLE OF CONTENTS ITEM 2: MATERIAL CHANGES........................................................................................................................... 2 ITEM 3: TABLE OF CONTENTS .......................................................................................................................... 2 ITEM 4: ADVISORY BUSINESS ........................................................................................................................... 4 ITEM 5: FEES AND COMPENSATION ................................................................................................................ 8 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................... 13 ITEM 7: TYPES OF CLIENTS ............................................................................................................................ 13 ITEM 8: METHOD OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS .................................... 13 ITEM 9: DISCIPLINARY INFORMATION ......................................................................................................... 17 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................ 18 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING .......................................................................................................................................................... 18 ITEM 12: BROKERAGE PRACTICES ................................................................................................................ 19 ITEM 13: REVIEW OF ACCOUNTS ................................................................................................................... 22 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ..................................................................... 22 ITEM 15: CUSTODY .......................................................................................................................................... 22 ITEM 16: INVESTMENT DISCRETION ............................................................................................................. 23 ITEM 17: VOTING CLIENT SECURITIES .......................................................................................................... 23 ITEM 18: FINANCIAL INFORMATION ............................................................................................................. 23 Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 3  ITEM 4: ADVISORY BUSINESS Castleview Partners, LLC (“Castleview”, the “firm” or “we”) is registered with the Securities and Exchange Commission (“SEC”) as a Registered Investment Adviser (“RIA”) with our principal place of business located in Dallas, Texas. We began conducting business in October 2015. Castleview is majority owned by Gill Capital Management, Inc. Douglas Gill is the sole owner of Gill Capital Management, Inc. The other two principals with management influence are Umberto Perez and David Fajardo. DIRECT ADVISORY SERVICES Our main investment advisory business is to manage the investment portfolios of individuals, high- net- worth individuals, corporations, non-profits, and retirement plans (each a “Client” and collectively the “Clients”). Our investment advisory services are tailored to the individual needs of our Clients and are based on the Client’s goals, investment objectives, time horizon, and risk tolerance. In this capacity, we and our Investment Advisor Representatives (each an “IAR” and collectively “IARs”), act as fiduciaries to our Clients, always acting in the best interest of our Clients. We offer the following investment advisory services through our IARs: 1) ADVISOR DIRECTED MANAGED ACCOUNTS IARs provide continuous investment advice to our Clients regarding the investment of the Clients’ portfolio holdings based on the individual needs of each Client. The IAR and the Client discuss the Client’s particular financial circumstances and establish goals, investment objectives, time horizons, and risk tolerance. The IAR reviews and discusses the Client’s prior investment experience, and may use the Risk Tolerance Questionnaire (“RTQ”) to develop a full understanding of the Client’s investment needs and constraints. An Advisor Directed Managed Account is one in which the account and the selected investments are managed by the IAR. The IAR assesses prevailing economic and market conditions, weighs the Client’s objectives, and then makes investment decisions as to securities to be bought and sold, as well as the timing of such purchases and sales, within the Client portfolio of holdings, on a discretionary basis. Our IARs utilize a variety of investments including, but not limited to: stocks; bonds; open- and closed- end mutual funds; no-load or load-waived mutual funds; Unit Investment Trusts (“UITs”); Exchange Traded Funds (“ETFs”); and derivative instruments such as index and stock options; Certificates of Deposit (“CDs”); and non-traded alternative asset class holdings, such as Limited Partnerships, Business Development Corporations, and Real Estate Investment Trusts. Because each type of investment holding or security involves a varying degree of risk, a particular security, and the associated weighting to that security, is only selected when it is determined to be consistent with and fit into the overall strategy for achieving the Client’s stated Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 4  goals, investment objectives, risk tolerance, time horizon, and liquidity needs. Our Clients may impose reasonable restrictions on investing in certain securities, types of securities, companies, and/or industry sectors. However, Castleview will refuse to accept or to continue management of the account or program, if your IAR determines that such restrictions imposed by the Client cannot be honored. If the Client refuses to modify or withdraw such restrictions after we have notified the Client that the restrictions cannot be honored, and given the Client an opportunity to withdraw or modify the restrictions, then an account will not be opened or, in the case of an existing account, the account will be closed. We will no longer be responsible for providing investment advice and implementing investment decisions to manage the account and the Investment Advisory Fee will cease. At that time, the account will become a retail brokerage account under the control of the Client. 2) THIRD PARTY MONEY MANAGER ACCOUNTS After gathering information about a Client’s financial circumstances, investment objectives, risk tolerance, and other data, our IAR assists the Client in allocating to a particular Third-Party Money Manager (“TPMM”) to deliver an investment model (“strategy”) or manage a separate account for the Client. IARs utilize multiple factors in selecting a prudent TPMM to recommend to a Client, including but not limited to performance, investment objectives, and fees. These factors are considered in relation to the Client’s specific goals and objectives to help determine suitability of the TPMM. Clients referred to a TPMM for the management of a separate account are directed to the disclosure documents and separate written agreements of the TPMM for more complete information regarding the terms and conditions of the relationship between the Client and the TPMM. When a Client engages a TPMM we recommended, we do not directly manage that portion of the Client’s portfolio assets and are not involved in selecting the securities to be bought and sold, or the timing of same. The day-to-day portfolio management decisions are provided by the TPMM, and then executed by us at the Client’s custodian or executed directly by the TPMM if managed in a separate account. In the event multiple TPMMs are recommended to a Client, each TPMM has differing minimum account requirements as well as a variety of fee ranges. If a Client uses a TPMM in a separate account, we periodically review the Client’s financial situation, objectives, and restrictions; and communicate relevant information to the TPMM, and assist the Client in understanding and evaluating the services provided by the TPMM. Some TPPMs maintain their own separate execution, clearing, and custodial relationships. If we determine that a selected TPMM is not managing the Client’s portfolio in a manner consistent with the Client’s IPS and investment objectives, or if the financial situation of the Client changes, we recommend a different TPPM. If we recommend the use of one of the strategies we manage internally, a conflict of interest may arise because we benefit from earning an additional fee, above the advisory fees, to manage the Castleview investment model to which Client funds are allocated. Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 5  3) COMBINED ADVISOR DIRECTED AND MONEY MANAGER MODEL ACCOUNTS In some cases, a Client account is managed as a blend of Advisor Directed and TPMM Models in which there are both selected investments managed by us and allocations to models that are managed by the TPMM in one single account. 4) FINANCIAL PLANNING Some of our IARs provide financial planning services. Fees are charged as a flat dollar amount or an hourly fee. Financial planning is a comprehensive evaluation, using assumptions and analysis of a Client’s current and future financial situation and needs, using variable data such as current and future income, expenses, investment growth, and performance, cash flows, asset values, and withdrawal plans. Through the financial planning process, questions, information, and analysis are considered as to how they may impact the current and future financial situation of the Client. To prepare a financial plan or analysis, we gather information from the Client though personal interviews. Information may include the Client’s tax status, current assets and liabilities, expenses, investment portfolio, future goals, investment return expectations, and attitudes towards risk. The financial plan or analysis is provided to help our Client make informed decisions with their financial resources in an effort to achieve their financial goals and objectives. In general, the financial plan or analysis may address any or all of the following areas: Asset allocation, education planning, estate planning, financial, insurance needs, retirement planning, and business retirement planning. The financial plan or analysis does not always contain our recommendations to purchase or sell specific securities. When investment recommendations are included, the Client decides whether or not to implement the recommendations we make, and whether they will implement such recommendations through Castleview or elsewhere. The services provided in the Financial Planning Agreement terminate upon the delivery of the financial plan or analysis to the Client, unless the IAR and Client enter into an On-going Planning Agreement. To the extent the Client implements recommendations contained in the financial plan, the IAR could be acting in the capacity of a registered representative of a broker-dealer. The IAR is limited to soliciting, offering, and selling only those investments approved through their broker- dealer. This may create a conflict of interest, as the IAR may be compensated for recommending specific investments in addition to the financial planning fee. Similarly, insurance product recommendations are limited to the insurance companies with which the IAR is appointed as a licensed insurance agent or broker. Your IARs Brochure 2B will provide details if he or she is registered with a broker-dealer or licensed as an insurance agent. Castleview both sponsors and provides investment management services through a wrap fee program called the Multiple Strategy Portfolio Program. Regardless of whether an account is Advisor Directed or utilizes TPMMs, as described above, there is no difference in how we manage accounts between the wrap and non-wrap format. Accounts in the wrap program have the cost of custody/execution (whether transaction-based or asset-based) included in the Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 6  overall “wrap fees” charged to the account. As such, we receive a portion of the overall wrap fees charged on such accounts. See Item 5 of this brochure for additional information on Wrap Program Fees PLATFORM SERVICES – aiAlpha In addition to the Direct Advisory Services detailed above, we provide advisory, sub-advisory, and operational support services to other investment advisory firms (“RIA Clients”) through our aiAlpha platform. aiAlpha provides RIA Clients with a cloud-based practice management system and a model marketplace with access to model portfolios and strategies of TPMMs. Designed to be an end-to-end solution for advisory firms, the aiAlpha platform delivers a comprehensive suite of administrative, operational, and trading services to RIA Clients. aiAlpha’s open architecture is custodian agnostic and customizable/scalable to the specific business needs of each RIA Client. aiAlpha’s practice management system can be engaged in a variety of ways: (1) administered and operated by the RIA Client’s internal staff, (2) account administration and operational support services provided by Castleview’s aiAlpha Service Team, or (3) a combination of both (1) and (2). RIA Clients utilize the models provided by the TPMMs, through aiAlpha, for the allocation of their client (“End Clients”) portfolios and/or offer RIA Advisor Directed services in which the RIA Client’s internal investment professionals work individually with the End Clients. The RIA Client’s financial professionals provide the specific advice concerning the selection of TPMMs, separately managed accounts, ETFs, or mutual funds that are available on aiAlpha. RIA Clients are responsible for ensuring that their financial professionals provide regular and ongoing contact with End Clients, allowing End Clients the opportunity to update and change their financial or personal profiles. The RIA Client’s financial professionals are responsible for informing us of any restrictions which End Clients wish to impose regarding the management of their accounts. The RIA Clients retain sole responsibility for determining whether a TPMM’s or RIA Advisor Directed portfolio or strategy is suitable and appropriate for the End Clients. We reserve the right to cancel services if we are not able to accommodate the restrictions requested by an End Client. TPMMs available on aiAlpha are either internally-sourced by Castleview or added at the request of an RIA Client. We perform initial and ongoing due-diligence on internally-sourced TPMMs and such TPMMs are made available to Clients. RIA Clients that request to have specific TPMMs added to aiAlpha bear all responsibility for the due diligence of requested TPMMs and the related suitability for their Clients. Such TPMMs are not endorsed by Castleview. We reserve the right to add or remove TPMMs from the platform in our sole discretion. TPMMs provide trade signals to us through aiAlpha for us to facilitate trades in the Client accounts. Our internal IARs utilize the aiAlpha Platform for Client portfolio management and administration. While aiAlpha is designed and intended to provide efficiency to our overall advisory practice, and our Clients incur no additional cost as a result of our use of aiAlpha, Clients should consider it when evaluating us due to the resources and human capital required for its operation. Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 7  ASSETS UNDER MANAGEMENT As of December 31, 2024, the firm had approximately $3,144,058,871 in total assets, of which $331,678,271 constitutes Regulatory Assets Under Management (“AUM”) and $2,812,380,600 represents Assets Under Administration (“AUA”) for RIA Clients of the aiAlpha platform. ITEM 5: FEES AND COMPENSATION DIRECT ADVISORY SERVICES Our Investment Advisory Fees are charged based on a percentage of assets under management and charged either quarterly or monthly by debiting the Investment Advisory Fees from Client accounts, as specified and further explained below. The Investment Advisory Fee will range from .50% to 1.75%, annually. In situations where a Client wishes to maintain a particular securities position or positions within an Investment Advisory Account, referred to as a Protected Position(s), the market value of the Protected Position(s) is assessed the Advisory Fee described below. Under no circumstances will we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. We established our Investment Advisory Fee schedule (included in this brochure) to create a framework of understanding for prospective Clients. The actual fee we assess each Client is negotiable and reviewed on a Client-by-Client basis. Our Investment Advisory Fee is based on a number of factors including, but not limited to, the complexity of the Client’s situation, amount of assets managed, anticipated future additional assets, related accounts, portfolio style, account holdings, manager selection, time involved, and the Client’s particular circumstances. The Client’s specific annual fee schedule is delivered in writing in the Client Management Agreement. That schedule is complete with a definition of terms and calculations and specifies what portfolio costs are and are not included in the fee. The following fee schedule covers the Advisory Fee, which is the compensation that goes to your advisor (also referred to as IAR) and includes the cost of our back-office administrative services. The Value column allows Clients to combine the value of all accounts into a household aggregate amount to achieve a break- point of lower fee rates. Not included in this fee schedule is the cost of TPMM model strategies or Castleview model strategies. The fee for the investment models is detailed later in this brochure. Investment Advisory Fees charged by other investment advisers may be similar to, more, or less than the fees assessed by Castleview. MAXIMUM ANNUAL ADVISORY FEE SCHEDULE Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 8  Managed Account Portfolio Value Fee Percentage First $500,000 Next $500,000 Next $4,000,000 Next $5,000,000 $10,000,001 and above 1.75% 1.50% 1.25% 0.50% Negotiable Model Management Fees for investment models (strategies) we develop and manage internally are based on a percentage of assets under management allocated to the model and charged quarterly. Model Management Fees range from .00% to 1.00% annually based on the model selected and are negotiated based on the total relationship with the Client, but typically fall between .20% to .50% annually. Model Management Fees for investment models (strategies) provided by TPMMs are based on a percentage of assets under management allocated to the model and charged quarterly. Model Management Fees for TPMMs range from .35% to 1.00% annually based on the model selected. The cost of our investment advisory and model management services may be more or less than the cost of purchasing similar services separately. For example, an unmanaged direct investment in a mutual fund, ETF or variable annuity sub-account would be less expensive than participation in an advisory account, because the Client would not bear our Investment Advisory Fee nor our Model Management Fee. There is no assurance that paying a model management fee for a model strategy will yield better performance than simply buying and holding the same underlying position(s) held by a model. Variable annuity accounts may be subject to transaction costs in connection with portfolio rebalancing as provided in the Prospectus delivered to the Client by the variable annuity issuer. Such costs, if incurred, would be in addition to our Investment Advisory Fee. FEE CALCULATION BASIS Clients pay an Investment Advisory Fee for advisory services rendered by Castleview and, in most cases, a Model Management Fee for model strategies. The value figure used in the fee calculation is the average daily balance computed at the close of business each trading day. In computing the Average Daily Balance in the account, shares of any mutual funds are valued at their respective net asset value as calculated on the valuation date in accordance with each fund’s prospectus. The value for stocks, bonds, options, and other securities is the closing price provided by custodians and/or reputable pricing services. You should not deem valuation, for fee calculation purposes, as a guarantee with respect to the marketability/liquidation value of those assets. ARREARS BILLING EXPLAINED The arrears billing method means that Clients pay for advisory services after we have rendered such services. Each account incurs a Total Account Fee comprised of the combined sum of the Advisory Fees and the Model Management Fees. Billing periods are based on the calendar quarter or month. Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 9  The first partial billing period is the actual number of days from the inception of the account to the end of the first quarter or month. All subsequent billing periods are based on the total number of days in the calendar quarter/month. The Total Account Fee is calculated by multiplying the account’s Average Daily Balance by the applicable Annual Advisory Fee, weighted for the number of days in the period, divided by 365, and then adding any Model Management Fees which are calculated by multiplying the Annual Model Fee by the percentage weighting of the account’s allocation to the model. The calculated Total Account Fee is deducted from Client’s account within the first week after the commencement of the new billing period. ADVANCE BILLING EXPLAINED The advance billing method means that Clients pay for our advisory services prior to the services being rendered. Each account incurs a Total Account Fee comprised of the combined sum of the Advisory Fees and the Model Management Fees. Billing periods are based on the calendar quarter/month. The inception billing occurs immediately following the end of the inception month. The inception billing is calculated by multiplying the starting value by the applicable Advisory Fee rate for the number of days remaining in the calendar quarter/month divided by 365. For all subsequent full quarters/months, the billing is calculated by multiplying the Average Daily Balance of the previous calendar quarter/month by the applicable annual Advisory Fee weighted for the number of days in the forward quarter/month divided by 365, and then adding any Model Management Fees, which are calculated by multiplying the similarly calculated Model Management Fee by the percentage weighting of the account’s allocation to the model. The calculated Total Fee is deducted from Client’s account during the first week after the commencement of the next billing period. AUTHORITY Our Clients authorize us to charge their account automatically for all Account Fees payable with respect to the account. The Account Fees are deducted from the Client’s account within the first week after the commencement of each billing period. Each Client is responsible for verifying the accuracy of any fee calculation. Clients should bear in mind that the custodian will not determine whether our computation is correct. The amount of the fees we debited can be found on the custodian account statements. EMBEDDED OPERATING EXPENSES Any mutual funds, ETFs, or variable annuity sub-accounts included in accounts bear their own internal operating expenses. Such internal expenses are in addition to our fees. Information on the amount and calculation of expenses for each of the mutual funds and ETFs is set forth in the fund’s prospectus and periodic reports provided, by the fund, to the Client. Information concerning the amount and calculation of expenses of each variable annuity sub-account and any other expenses Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 10  assessed by each variable annuity issuer are contained in the prospectus delivered to the Client by the variable annuity issuer. CUSTODIAL, BROKERAGE, AND OTHER TRANSACTION COSTS The custodian selected for the account(s) custodies (“holds”) the account assets, often executes trades in the account, and provides other account related services. The custodian charges fees and/or commissions for their services (“Custodial Charges”). If a Wrap Fee Approach is selected (as described below), the annual Advisory Fee includes the cost of basic custody services, meaning we cover this expense from the total fee we assess Clients. If the Client selects a non-wrap fee arrangement, the Custodial Charges are assessed to the Client account in one of two ways: 1) TRANSACTION-BASED PRICING METHOD With this selection, the Custodial Charges related to trading within the account are charged by the custodian per ticket, or per trade, when a buy or sell transaction is executed. Thus, the more active the trading, the more this method costs the Client. These ticket charges differ among custodians and information specific to a custodian, including a commission schedule, can be obtained from the IAR. This expense is separate from, and does not include, the investment advisory fee charged by Castleview. 2) ASSET-BASED PRICING METHOD With this selection, the investment advisory account is charged a flat annual basis point fee on chargeable asset value held in the account, with no additional Custodial Charges for each buy or sell transaction executed. Thus, the less active the trading, the more inefficient this method, compared to paying per ticket commissions. The fee is assessed on the average daily balance of the chargeable assets. This expense is separate from, and does not include, the investment advisory fee charged by Castleview. 3) FLAT FEE PRICING METHOD With this type, the custodian assesses each account with a flat annual charge and usually debits this amount in four quarterly installments.Transaction-based pricing may be beneficial if the trading activity in the account is infrequent. If the trading activity becomes frequent and remains so, transaction-based pricing may be less cost effective than asset-based pricing. The rates for transaction-based and asset-based vary among custodians and is disclosed in detail in separate documentation at the time of contracting. Clients should consult with their IAR to discuss the best option for their circumstances. WRAP FEE APPROACH A Wrap Fee Program is an investment advisory program in which Client pays one fee for both investment advisory services and the cost for trading in the account. The “wrap fee” is not based directly on the actual transaction or execution costs for the transactions within the account(s). Depending on the underlying investments within the program and how much actual trading activity occurs, participants in a Wrap Fee Program could pay more or less than if they elected to subscribe Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 11  to a non-wrap fee program and pay for transactions costs separately. When executing the Client Management Agreement, the Client’s selection is stipulated in the Acceptance of Terms (as defined therein), which is made a part of the final Client Management Agreement. The benefits under a Wrap Fee Program depend, in part, upon the size of the account, the management fee charged, and the number of transactions likely to be generated in the account. For example, a Wrap Fee Program may not be suitable for accounts with little trading activity. In order to evaluate whether a Wrap Fee Program is suitable, Clients should compare fees and any other costs we assess with those that would be charged by other advisers, broker-dealers, and custodians for advisory fees, brokerage and other execution costs, and custodial services. Clients should consult with their IAR to discuss the best option for their circumstances. If the Client elects to participate in the Wrap Fee Program, we will provide the Client with a separate disclosure document that contains additional information. See Item 12 of this brochure for information on our brokerage practice. FEE SHARING ARRANGEMENTS From time-to-time we will enter into agreements with fund managers to help them get assets into their fund. We do this through creating awareness among our industry relationships. These relationships include strategists, advisors, fund managers, brokers, and clients of the firm. As compensation for these introductions, we will generally be paid a percentage of the fund manager’s fee. There is a financial incentive created by these arrangements for the firm to recommend the use of one of the products covered. To address this conflict, we reduce our model fee to Clients to avoid “double-dipping” of fees. TERMINATION OF THE CLIENT MANAGEMENT AGREEMENT The Client Management Agreement may be cancelled at any time, by either party, for any reason, without penalty. Termination by the Client is effective upon our receipt of the Client’s written notice unless it includes a request for, and we agree to, a later date. Unless otherwise stipulated in the notice provided to the Client, termination by us is effective thirty (30) days from the date of the written notice. The Client may terminate the Client Management Agreement within five business days of its execution. Upon termination of an account, any pre-paid, unearned fees are promptly refunded to the Client. In calculating a Client’s reimbursement of fees, Castleview prorates the amount owed according to the number of days remaining in the billing period. Clients are required to provide proper written notice to terminate the Client Management Agreement. Should a Client make excess withdrawals from their account, transfer funds to another custodian, or otherwise disable our custodial account authority, without notice, trade errors may occur. In such circumstances, the Client is financially responsible for any resulting fees and/or losses associated with the trade error. Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 12  ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Castleview does not charge performance-based fees. The Client’s Advisory Fee is calculated based on the value of the Client’s account, not the performance of the account. ITEM 7: TYPES OF CLIENTS We generally provide investment advisory services to individuals, including high net worth individuals, for both taxable and retirement assets. Though not as common, we may also provide services to pension and profit sharing plans, charitable organizations, and corporations or business entities. ITEM 8: METHOD OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS METHODS OF ANALYSIS Each of our affiliated IARs formulates their individual investment strategies. To aide this process, IARs may select from a variety of sources to obtain information and data concerning securities. The main information sources include, but are not limited to: • Financial programs and financial websites; • Financial newspapers and magazines; • Research materials prepared by others; • Timing services; • Annual reports, prospectuses, regulatory filings; and/or • Company press releases The IARs may use charting and fundamental and/or technical analysis methods to formulate the investment advice they provide to their Clients. Clients are advised to become familiar with the sources of information used by their IAR and to ask any questions that they may have regarding those information sources. INVESTMENT STRATEGIES Investment strategies used by our IARs include, but are not limited to: Interest or dividend income; • Asset allocation with rebalancing; • Capital preservation; • Active trading; • • Margin transactions; • Options trading; and • Hedging Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 13  Prior to investing, Clients should ensure that they fully understand and agree with the investment strategy proposed by their IAR. RISK OF LOSS GENERAL Investing in securities involves risk of loss that Clients should be prepared to bear. We do not represent or guarantee that we can predict future results, successfully identify market tops or bottoms, or insulate our Clients from losses due to market corrections or declines. The prices of, and the income generated by, equities and other securities held in the portfolio may decline in response to certain global events, including those directly involving the issuers of such securities. General risk factors include, but are not limited to, conditions affecting the general economy; overall market changes; local, regional, or global political, social, or economic instability; governmental responses to economic conditions; and currency fluctuations, interest rate changes, inflation, and commodity price fluctuations. We cannot guarantee that a Client’s financial goals and objectives will be met. Past performance is not indicative of future results. The value of a Client’s assets will be subject to a variety of factors, including the liquidity and volatility of the securities markets. Portfolio transactions may give rise to tax liability, for which the Client is responsible. ASSET ALLOCATION RISK Asset allocation risk is the risk that a Client’s assets may be allocated to an asset class that underperforms other asset classes. For example, fixed-income securities may underperform equities. Accordingly, asset allocation risk will be influenced by the allocation among equities, fixed income, and money market funds. INVESTMENT AND MARKET RISK Recommendations are subject to investment risk, including the possible loss of the entire principal amount invested. A recommendation to invest in securities and other instruments may also involve market risk, which is the risk that the value of the investments may increase or decrease, sometimes rapidly and unpredictably. The current value of a security or other instrument may be worth less than the amount of the original investment, even after taking into account reinvestment of any distributions. MODEL RISK Where the management of an Advisory Account includes the use of various proprietary and third- party advised quantitative or qualitative models (strategies), it should be expected that there may be deficiencies in the design or operation of these models, including shortcomings or failures of processes, people or systems. Investments selected using models may perform differently than expected as a result of the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, the speed that market conditions change and technical issues in the Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 14  construction and implementation of the models (including, for example, data problems and/or software issues). The use of investment models, electronic trading, and software programs to calculate trades, in contrast to person-to-person manual trading, could be adversely impacted by software or hardware malfunction and other technological failures, power loss, software bugs, malicious code such as “worms,” viruses or system crashes or various other events or circumstances within or beyond the control of Castleview or their affiliates. Certain of these events or circumstances are difficult to detect. All model trading is processed on a “best efforts” basis dependent on availability of accurate data, correct and complete software calculations, and successful and timely trade delivery to custodians, among other factors. Execution of model trading signals might not be completed during the current market session due to these implementation factors, and/or must be executed in the next market session, if necessary. In some instances, account-level changes combined with model-level changes in the same market session can work at cross purposes, one serving to increase or decrease exposure to a specific security while the other moves the position in the opposite direction. These outcomes are inherent to managing investments through the model allocation approach. Moreover, the effectiveness of a model may diminish over time, including as a result of changes in the market and/or changes in the behavior of other market participants. Models may not be predictive of future price movements if their return mapping is based on historical data regarding particular asset classes, particularly if unusual or disruptive events cause market movements, the nature or size of which are inconsistent with the historical performance of individual markets and their relationship to one another or to other macroeconomic events. In addition, certain strategies can be dynamic and unpredictable, and a model used to estimate asset allocation may not yield an accurate estimate of the then current allocation. Models also rely heavily on data that is licensed from a variety of sources, and the functionality of the models depends, in part, on the accuracy of voluminous data inputs. Operation of a model may result in negative performance, including returns that deviate materially from historical performance, both actual and pro forma. Additionally, commonality of holdings across quantitative investment managers may amplify losses. There is no guarantee that the use of these models will result in effective investment decisions for an advisory account. TRADING RISK Model Managers, Advisors, and Fund Managers deliver strategies that call for the use of certain styles or manner of trading or trade orders. In substantially all cases, “Market” orders are used by model strategists. Market orders are executed at a price beyond the control of Castleview, or its affiliates. With all market orders, the execution price that will be achieved by the broker-dealer responsible for executing the order is not known at the time the order is delivered. In the case of model trade calculation, Castleview calculates the share quantity to be bought or sold to match position weights targeted by the strategist based on the most recently available market price for the security being traded. It is a certainty that the actual price at which the market order executes will differ from the price used by the system in the calculation of share quantities. This is particularly true in volatile market conditions where prices are moving rapidly. Therefore, Castleview and their affiliates bear no responsibility for differences in actual trade size versus target trade size resulting from a market price Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 15  change occurring after the trade is calculated by Castleview. Further, it should be understood that for strategists who direct the use of market-on-close (MOC) orders, any over-buys or over-sells cannot be corrected until the next trading session which could result in substantial corrections due to market volatility. Further, for strategists who employ the use of mutual funds in models, any adjustments to actual versus target weights due to price movement cannot be made until the next trading session’s closing NAV per share, which could be materially different from the previous day. In these instances, Castleview bears no financial responsibility for any requested or necessary adjustments to model target weights resulting from the execution price differing from the price used by Castleview to create the trade file. REBALANCING RISK The risk that an Advisory Account’s actual allocation is out of balance with the target allocation is born by the Account owner. Any rebalancing of such assets may be infrequent and limited by several factors and, even if achieved, may have an adverse effect on the performance of the Advisory Account’s assets. CYBER SECURITY RISK The risk of actual and attempted cyber-attacks, including denial-of-service attacks, and harm to technology infrastructure and data from misappropriation or corruption, and reputation harm. Due to our system’s interconnectivity with third-party vendors, central agents, broker-dealers, clearing houses and other financial institutions, Castleview, and thus indirectly the Advisory Accounts, could be adversely impacted if any of them is subject to a successful cyber-attack or other information security event. Although Castleview takes protective measures and endeavors to modify them as circumstances warrant, its computer systems, software and networks are vulnerable to unauthorized access, misuse, computer viruses or other malicious code and other events that could have a security impact or render Castleview unable to transact business on behalf of Advisory Accounts. Castleview does not control such events, and thus, bear no financial responsibility for the outcome. DATA RISK The risk that information from third-party data sources to which Castleview subscribes is incorrect. Central to everything the system does, from displaying content for advisors who evaluate client accounts, to the reporting of account activity and performance, to the calculation of trades, is data from third parties. The daily volume of this data, from transactions, prices, corporate actions, alerts, etc. that is brought into the system makes it impossible to monitor and detect any or all errors in such data. This risk is inherent to portfolio management and accounting systems. Castleview quickly addresses errors found or reported in the data, but does not provide assurance that any data consumed into its portfolio software or relied on in trading or reporting, is accurate. Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 16  EXCHANGE TRADED FUND RISK The risk that ETFs fail to accurately track the market segment or index that underlies their investment objective. Moreover, ETFs are subject to the following risks that do not apply to conventional funds: (i) the market price of the ETF’s shares trade at a premium or a discount to their net asset value; (ii) an active trading market for an ETF’s shares are not developed or maintained; and (iii) there is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged. Castleview, at times, purchases in Advisory Accounts leveraged and inverse ETFs where strategists believe it is warranted, based on the invested portfolio’s objective. These securities carry certain specific risks to investors. Leveraged ETF shares typically represent interest in a portfolio of securities that track an underlying benchmark or index and seek to deliver multiples of the performance of the index or benchmark. An inverse ETF seeks to deliver the opposite of the performance of the index or benchmark it tracks. Like traditional ETFs, some leveraged and inverse ETFs track broad indices, some are sector specific, and others are linked to commodities, currencies, or some other benchmark. To accomplish their objectives, leveraged and inverse ETFs pursue a range of investment strategies using swaps, futures contracts, and other derivative instruments. Most leveraged and inverse ETFs “reset” daily, meaning that they are designed to achieve their stated objectives daily. Their performance over longer periods of time, over weeks or months or years, can differ significantly from the performance (or inverse of the performance) of their underlying index or benchmark during the same period. This effect can be magnified in volatile markets and thus poses substantial risk for an investor. OPERATIONAL RISK The risk of loss arising from shortcomings or failures in internal processes or systems at Castleview or their affiliates, external events impacting those systems and human error. Operational risk can arise from many factors ranging from routine processing errors to potentially costly incidents such as major system failures. Some Advisory Accounts trade instruments on a very active, tactical basis, where operational risk is heightened due to the nature of such trading patterns and swings in market prices. TRADE RESTRICTION RISK The risk that temporary or permanent trading restrictions may be imposed on securities (including ADRs, ADSs, ETFs, US common stocks, exchange traded derivatives, crypto currency, or other securities) or options in a client’s account, or the risk that a client’s account itself is restricted from trading due to issues such as mail-holds, death of the account owner, or Reg-T violations. In such instances, trades might have to be canceled that cannot be allocated to the restricted account, securities might have to remain in an account despite the desire to sell them, and the account might otherwise be out of balance with the intended target allocations. All of these outcomes could have a significant cost to a client that are beyond the control of Castleview. ITEM 9: DISCIPLINARY INFORMATION Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 17  Registered investment advisers are required to disclose all facts regarding any legal or disciplinary events that would be material to a Client’s evaluation of the adviser or the integrity of its management. Neither Castleview, nor our owners or management have been involved in any criminal, legal, or disciplinary events that would have a negative material impact on a Client’s evaluation of our advisory business or reflect negatively on the integrity of management. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS As discussed in Item 4, we operate the aiAlpha Platform providing administrative and operational support services to other investment advisory firms. These investment advisory firms are not affiliated with us; they are clients for which we provide certain support services. Please refer to Item 4 for additional details. As discussed in Item 5, we will from time-to-time enter into certain agreements with fund managers to assist in the distribution of their fund, normally an exchange-traded fund, a mutual fund, or a limited partnership. We do this by making introductions of these managers/products to our network of industry relationships. These products could also be used in Client accounts, which is a natural conflict of interest. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING CODE OF ETHICS Castleview’s Code of Ethics sets forth a general standard of business conduct that we expect of all personnel (collectively, “employees”). Our employees must uphold high standards of ethical conduct in their relationships with Clients, one other, Castleview management, vendors, and the public. Our Code of Ethics details such items as conflicts of interest, protection of non-public personal information, personal securities trading, reporting of violations, recordkeeping requirements, outside business activities, gifts and gratuities, and privacy considerations. Failure to uphold the Code of Ethics; or violations of applicable laws, rules, or regulations; may result in disciplinary action, including termination of employment with Castleview and notification of such violation to the appropriate regulatory authority. Clients may request a copy of our Code of Ethics and one will be provided free of charge. PERSONAL TRADING Our IARs, employees, and related persons may buy, sell, or hold, in their personal accounts, the same securities we recommend to Clients. Conversely, Castleview personnel may take investment positions different than or contrary to those of our Clients. Occasionally, transactions for Castleview Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 18  personnel may be executed at about the same time they are executed for a Client’s account. This may create a conflict of interest, whereby the employee or related person places their order ahead of a Client’s order and, as a result, obtains a better price than the Client. While we do allow our personnel to invest in the same securities that Clients buy and sell, we do not allow orders to be knowingly placed ahead of Clients. Systematically trading ahead of Clients is known as front-running and is strictly prohibited. All personal securities transactions are subject to monitoring in order to ascertain any patterns of conduct which may evidence conflicts with the Code of Ethics, including patterns of front-running or other inappropriate behavior. ITEM 12: BROKERAGE PRACTICES GENERAL PRACTICES We arrange for the execution of securities transactions for Client accounts through broker-dealers that we reasonably believe will provide best execution. In selecting a broker or dealer, we consider, among other things, the broker-dealer's execution capabilities, the reputation of the broker-dealer and the broker- dealer’s access to the markets for the securities being traded. When selecting broker-dealers to execute Client transactions, we consider factors such as execution speed, reliability, cost, quality of trade execution, and the availability of services and products. The rate that a Client pays for such services may be higher than the rate available at other brokerage firms. We believe the benefits and features of recommended brokerage firms are of sufficient value to warrant a Client paying a potentially higher explicit transaction cost than could be achieved at other such firms. Put simply, price is not the sole, or even most important, factor when selecting where a Client trade is executed. Generally, we seek competitive commission rates, but do not necessarily attempt to obtain the lowest possible commission for transactions for the account. Our decision to purchase or sell securities for our Client accounts is based on the specific investment objectives, guidelines, restrictions, and circumstances of each account. We attempt to allocate, to the extent operationally and otherwise practical, investment opportunities to each Client over a period of time on a fair and equitable basis relative to other Clients. In the event a trade error results in a capital gain to Castleview in excess of $100, the gain will be donated to a 501(c)(3) organization of our choosing, currently the Tunnels to Towers Foundation, subject to change without prior notification. From time to time, recommended broker-dealers may refer Clients to us. Such referrals could provide an incentive for us to engage their execution services; however, these potential referrals are not material in size or volume and would not negatively influence the level of care towards Clients’ accounts. In most cases, transactions will be executed through a broker-dealer that also serves as the custodian of the Client’s funds. Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 19  INSTITUTIONAL ADVISOR PROGRAMS We participate in the institutional advisor programs (each referred to as “Program”) offered by Fidelity Institutional and Charles Schwab Advisor Services. Fidelity Institutional, member FINRA/SIPC/NFA (“Fidelity“), an unaffiliated SEC-registered broker-dealer and FINRA member, and Schwab Advisor Services (“Schwab”) is a business segment of The Charles Schwab Corporation, serving advisors through Charles Schwab & Co., Inc, FINRA Member, also unaffiliated with us. Fidelity and Schwab offer independent investment advisors services which include custody of securities, trade execution, clearance, and settlement of transactions. We receive some benefits from Fidelity and Schwab through our participation in these Programs. As disclosed above, we participate in the programs, and we may recommend Fidelity or Schwab to Clients for custody and brokerage services. There is no direct link between our participation in the Programs and the investment advice we give to our Clients, although we receive economic benefits through our participation in the Programs that are typically not available to Fidelity or Schwab retail investors. These benefits include the following products and services (provided without cost or at a discount): • Receipt of duplicate Client statements and confirmations; • Research related products and tools; • Consulting services; • Access to a trading desk serving participating advisors; • Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); • The ability to have advisory fees deducted directly from Client accounts; • Access to an electronic communications network for Client order entry and account information; • Access to mutual funds with no transaction fees and to certain institutional money managers; and • Discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third party vendors. Fidelity or Schwab may also pay for business consulting and professional services received by Castleview affiliates. Some of the products and services made available by Fidelity and Schwab through these Programs benefit us but may not benefit our Client accounts directly. These products or services may assist us in managing and administering Client accounts, including accounts not maintained at Fidelity or Schwab. Other services made available by Fidelity and Schwab are intended to help us manage and further develop our business enterprise. The benefits we receive through participation in these Programs do not depend on the amount of brokerage transactions directed to Fidelity or Schwab. However, we do benefit financially from transition assistance these firms make available, which can take the form of cash payment, loans, or administrative support, so we might have an incentive to maintain Client assets at these firms over some other firm not offering transition assistance. As part of our fiduciary duties to Clients, we endeavor, at all times, to put the interests of Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 20  our Clients first. Clients should be aware, however, that the receipt of economic benefits by Castleview or its related persons, in and of itself, creates a potential conflict of interest and may indirectly influence our choice of Fidelity or Schwab for custody and brokerage services. The SEC recently changed the wording of certain questions on the Form ADV and has indirectly changed the definition of soft dollars. Due to the new wording, the receipt of goods and/or services from a third party in connection with providing advice to clients could be seen as soft dollars. Although the aforementioned additional services we receive from the Schwab and Fidelity would fall under this description of soft dollars, we do not participate in any formal soft dollar arrangements with either of these firms. In limited cases, we might recommend the use of RBC Advisor Services or Interactive Brokersfor custody services for accounts accessing certain types of trading strategires, others involving non- standard assets, or for accounts owned by U.S. residents living abroad, resident aliens, or certain types of corporate entities. SOFT DOLLARS This is the practice whereby a portion of the commissions associated with certain Client securities transactions are used to acquire research products and services from a broker-dealers or a designated third-party. Because such products and services provide a benefit to us, this creates a potential conflict of interest in the allocation of Client brokerage. Currently the firm has no such active Soft Dollar arrangements. TRADING PROCEDURES We employ the following trading procedures in connection with discretionary accounts: • When we believe it is desirable, appropriate, and feasible to purchase or sell the same security for a number of our advisory Clients at the same time, when possible, we aggregate Clients' orders in what is commonly known as a block order that seeks to obtain more favorable executions, in terms of the price at which the security is purchased or sold, and/or the efficiency with which the transaction is processed. All Client accounts participating in a block trade at a given custodian are allocated shares at the same average price. • When it is not possible to process the trade on a block basis, trades are processed on a rotating basis, so as not to systematically advantage or disadvantage any particular Client or group of Clients. • Although we place aggregated trades on an average price or rotating basis, as described above, there is no assurance that the actual execution of the block trades by the various custodians will occur in the same manner. • Once a block trade is completed for Clients holding assets at a particular custodian, allocation instructions are then provided to the custodian. The trade allocation process takes place on as timely a basis as possible, either as an order is completed in full, or, in the case of a Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 21  partially- executed block order, at the market's close when the average price can be calculated. • If the block order is not fully executed by the end of the trading day, allocation of the partially filled order is completed on a pro-rata basis, unless it is not practical to do so. Any deviation from a pro- rata process is performed in a fair and equitable method and the reason for the allocation method used is documented in writing no later than on the trading day following the day the order is executed. In the case of an account over which we do not exercise investment discretion, trades for the Client’s account are not executed at the same time as block trades for the discretionary Client accounts and, as a result, will not be executed at the same average price as discretionary accounts. ITEM 13: REVIEW OF ACCOUNTS IARs offer to meet with Clients no less frequently than annually to review Client’s account(s) and personal financial circumstances. Each calendar month or quarter, Clients receive a statement from their account custodian, listing all activity that occurred during the quarter. Additionally, we make available quarterly performance reports, showing how the Client’s investments have performed. Our personnel are available during normal business hours to answer Clients’ questions regarding activity and performance. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION From time to time, we pay a referral fee to a third-party person or entity for introducing Clients. Such fees are paid pursuant to SEC Rule 206(4)-3 regarding cash solicitation arrangements. The amount of the fee is a percentage of the total fee paid to manage the Client’s account. In no case is the Client fee marked-up in order to pay referral compensation. There is no direct link between our participation in the programs offered through custodian broker- dealers and the investment advice we give to Clients. Some of our IARs are registered representatives with a broker-dealer or appointed insurance agents with one or more insurance companies. These affiliations, although related to their work as our IAR, are considered an outside business activity. There is no requirement for our Clients to implement recommended transactions through the IAR in this outside capacity. Moreover, Clients should be aware that the IAR receives additional compensation from one of these affiliations related to such transaction that introduces the possibility of a conflict of interest. Clients are encouraged to obtain detailed information from their IAR regarding commission compensation related to the purchase of insurance products and investment in financial products outside of Castleview. ITEM 15: CUSTODY Neither Castleview nor any of our affiliates have custody of the assets in a Client’s account. An Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 22  unaffiliated custodian is recommended by the IAR and one is selected by the Client. The custodian sends an account statement, on at least a quarterly basis, which itemizes each of the current investment positions and all transactions that occurred in the Client’s account. We will also prepare a quarterly performance statement. The Client is advised to compare the two statements each quarter. In the event of a discrepancy, the custodian's statement will prevail as the official accounting record. Any discrepancies, errors, or questions should be brought to the attention of the Client’s IAR immediately. ITEM 16: INVESTMENT DISCRETION The Client grants investment discretion by signing a Client Management Agreement and through the custodian account documentation. The Client Management Agreement makes reference to an Investment Policy Statement ("IPS") which may be presented to the Client, by the IAR, describing the investment parameters. If the Client wishes to make changes to this discretion, it must be done in writing. ITEM 17: VOTING CLIENT SECURITIES Castleview does not vote proxies on behalf of Clients. Clients are instructed to read through the information provided with the proxy-voting documents and make a determination based on the information provided. Clients who own shares of common stock or mutual funds are responsible for exercising their right to vote as shareholders. Clients are free to contact their IAR to discuss pending votes. ITEM 18: FINANCIAL INFORMATION Neither Castleview nor our management has any adverse financial situations that would be expected to reasonably impair our ability to meet all obligations to our Clients. Neither Castleview nor any of our principals have been subject to a bankruptcy or financial compromise. We are not required to deliver a balance sheet along with this brochure as we do not collect advance fees for services to be performed six months or more in advance. Castleview Partners, LLC Form ADV, Part 2A: Brochure – 03/31/2025 Page 23