DOWLING FINANCIAL SERVICES, INC

The Dowling Group Wealth Management 1171 E. Putnam Avenue, #1B Greenwich, CT 06878 Tel.: (203) 967-2231 Fax: (203) 327-7999 www.thedowlinggroup.com March 14, 2025 FORM ADV PART 2A FIRM BROCHURE This brochure provides information about the qualifications and business practices of The Dowling Group Wealth Management. If you have any questions about the contents of this brochure, please contact us at (203) 967-2231. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about The Dowling Group Wealth Management is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for The Dowling Group Wealth Management is 155624. The Dowling Group Wealth Management is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training.  Item 2 – Material Changes The Dowling Group Wealth Management has the following material changes to report. Material changes relate to The Dowling Group Wealth Management’s policies, practices or conflicts of interest. • The Dowling Group Wealth Management has transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level. • Stephen Ng is no longer with the firm.  Item 3 - Table of Contents Item 4 Advisory Business 1 Item 5 Fees and Compensation 4 Item 6 Performance-Based Fees and Side-By-Side Management 7 Item 7 Types of Clients 7 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 7 Item 9 Disciplinary Information 9 Item 10 Other Financial Industry Activities and Affiliations 9 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 11 Item 12 Brokerage Practices 11 Item 13 Review of Accounts 12 Item 14 Client Referrals and Other Compensation 13 Item 15 Custody 14 Item 16 Investment Discretion 14 Item 17 Voting Client Securities 14 Item 18 Financial Information 14 Item 19 Requirements for State-Registered Advisers 15 Additional Information 15  Item 4 - Advisory Business The Company The Dowling Group Financial Management is a registered investment adviser based in Greenwich, Connecticut. We are organized as a corporation under the laws of the State of Delaware. We have been providing investment advisory services since 1989. Sean M. Dowling is our firm’s owner. The Advisory Business Currently, we offer the following investment advisory services, which are personalized to each individual client: • Portfolio Management Services • Financial Planning Services • Selection of Other Advisers The following paragraphs describe our services. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. You may see the term “Associated Person” throughout this Brochure. As used in this Brochure, our Associated Persons are our firm’s officers, employees, and all individuals providing investment advice on behalf of our firm. Portfolio Management Services We offer discretionary and non-discretionary portfolio management services to our clients and prospective clients. Once we construct an investment portfolio for you, we will monitor your portfolio’s performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. For non-discretionary accounts, we must obtain your approval prior to executing any transactions on behalf of your account. For discretionary accounts, we obtain your consent to have discretion over your account and you also sign a limited power of attorney to authorize us to make investment decisions on your behalf. Financial Planning Services We offer broad-based, modular, and consultative financial planning services to our clients and prospective clients. Broad-based financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you 1  may act on our recommendations by placing securities transactions with any brokerage firm. Selection of Other Advisers As part of our investment advisory services, we may recommend that you use the services of a third-party investment adviser (“TPA”) to manage your entire, or a portion of your, investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPA or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPA’s performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the TPA(s)’s performance to ensure its management and investment style remains aligned with your investment goals and objectives. Some TPAs will have discretionary authority over your assets under management. Types of Investments We generally offer advice on all exchange listed securities, over the counter securities, U.S. government securities, corporate bonds, certificates of deposit (CD's), mutual funds, municipal securities, variable life insurance, variable annuities, options on securities, warrants, alternative investments, and limited partnership interests in real estate, oil and gas, and equipment leasing. We do not provide advice for options and/or commodity futures; however, we may select an options or commodities separate account manager to manage our clients’ commodities/futures portfolios. Client Tailored Services and Client Imposed Restrictions; Portfolio Management Services investment objectives, risk tolerance, and other relevant Our investment advice is tailored to meet our clients’ needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine information (the your “suitability information”) at the beginning of our advisory relationship. We will use the suitability information we gather from our initial meeting to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Financial Planning Services If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we review and analyze the information you provide to our firm, we will deliver a written plan to you , 2  designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. Wrap Fee Program We do not participate in wrap fee programs (i.e. programs that offer services, including brokerage services, for one all-inclusive price.) 3  Assets Under Management As of 12/31/2024, we manage approximately $165,628,233 in client assets, $153,812,028of which is managed on a discretionary basis and $11,816,205 of which is managed on a nondiscretionary basis. Item 5 - Fees and Compensation Fees and Payment Portfolio Management Services Our fee for portfolio management services is based on a percentage of your assets we manage and is set forth in the following fee schedule: Assets Under Management Up to $1,000,000 $1,000,000 - $1,999,999 $2,000,000 - $4,999,999 $5,000,000 - $9,999,999 $10,000,000 - $14,999,999 $15,000,000 - $20,000,000 $20,000,000 + Annual Fee 1.25% 1.00% 0.90% 0.85% 0.80% 0.75% Negotiable Our annual portfolio management fee is billed and payable quarterly, in advance, as set forth in the investment advisor agreement between you and us. Fees are based on the value of your account on the last day of the previous quarter. In lieu of quarterly payments, you have the option to be billed monthly in advance based on the value of your account on the last day of the previous month. If the portfolio management agreement is executed at any time other than the first day of a billing period, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter (or month) for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. You may terminate the portfolio management agreement upon written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the 4  portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre- paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees equal to the proportionate amount of such fees that are attributable to the number of days in the quarter that remain after the effective date of termination. We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. Financial Planning Services We charge a fixed fee or hourly rate for broad-based financial planning services, which generally ranges between $2,500 and $20,000. The fixed fee is determined by estimating the amount of time we will spend on the plan, considering such factors as the complexity and scope of the desired plan. If you only require advice on a single aspect of your finances, we offer modular financial planning/general consulting services on an hourly basis. Our rate for such services is $500 per hour for our professional staff and. Our fee may be negotiable depending on the scope and complexity of the plan, your financial situation, and your objectives. An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you in advance and request that you approve the additional fee. Financial planning clients are expected to pay for services in advance. If you terminate a financial planning contract, you will incur a pro rata charge for services rendered prior to the termination of the agreement. We will provide you with an invoice for estimated financial planning fees, which will be due at the inception of the financial planning process. In some circumstances, we may permit you pay 50% of the fee in advance and the remaining portion upon the completion of the services rendered. You may terminate the financial planning agreement by providing written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Selection of Other Advisers 5  Advisory fees charged by third party advisors (“TPAs”) are separate and apart from our advisory fees. Assets managed by TPAs will be included in calculating our advisory fee, which is based on the fee schedule set forth in the “Portfolio Management Services” section in this Brochure. Advisory fees that you pay to the TPA are established and payable in accordance with the disclosure brochure provided by each TPA to whom you are referred. These fees may or may not be negotiable. You should review the recommended TPA’s disclosure brochure and take into consideration the TPA’s fees along with our fees to determine the total amount of fees associated with this program. In most cases, you will be required to sign an agreement directly with the recommended TPA(s). You may terminate your advisory relationship with the TPA according to the terms of your agreement with the TPA. You should review each TPA’s disclosure brochure for specific information on how you may terminate your advisory relationship with the TPA and how you may receive a refund, if applicable. You should contact the TPA directly for questions regarding your advisory agreement with the TPA. Additional Fees and Expenses As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund’s prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through which your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the “Brokerage Practices” section of this Brochure. 6  Compensation for the Sale of Securities or Other Investment Products We may recommend mutual funds or Exchange Traded Funds (“ETFs”) for investment by our clients. Some of these mutual funds are “no load” funds. We may recommend that you use a third-party adviser (“TPA”) based on your needs and suitability. You are not obligated, contractually or otherwise, to use the services of any TPA we recommend. Other Brokers and Agents You have the option to purchase investment products that we recommend through brokers or agents other than those we recommend to you. Item 6 – Performance-Based Fees and Side-by-Side Management We do not accept performance-based fees or participate in side-by-side management. Side- by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client’s account. Our fees are calculated as described in the Advisory Business section above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Item 7 - Types of Clients We offer investment advisory services to individuals, high net worth individuals, pensions and profit-sharing plans, corporations, and other business entities. In general, other than for the automated investment program, we require a minimum of $500,000 to open and maintain an advisory account. At our discretion, we may waive this minimum account size. For example, we may waive the minimum if you appear to have significant potential for increasing your assets under our management. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Our Methods of Analysis and Investment Strategies and Risks Involved In our portfolio management, we may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: 7  • Goal Based Investing – establishing client goals and developing investment policies to meet those goals. Risks for this type of investing include the risk that we may not fully understand a client’s goals or those goals may change, and that the investment policies we develop to meet those goals may not lead to the achievement of the goals. • Fundamental Analysis – involves analyzing individual companies, ETFs, mutual funds and/or fund managers and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. • Technical Analysis – involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. There is a risk in this type of analysis that past patterns and trends may fail to predict the actual behavior of the market and specific stocks. • Long Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. There is a risk with long-term purchases that the decision to hold the securities results instead in a loss because the securities decline in value rather than grow. Our investment strategies and advice may vary depending upon each client’s specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. Most of our strategies are based on long-term growth. Long term purchases may be affected by unforeseen long-term changes in the company in which you are invested or in the overall market. Margin accounts present special risks because you can lose more money than you deposit in your account. Additionally, the custodian can force the sale of securities in your account and can sell securities without contacting you. As disclosed in the “Advisory Business” section above, we may recommend that you use the services of a third-party investment adviser (“TPA”) to manage all or a portion of your 8  investment portfolio. You should review the TPA’s disclosure brochure for information regarding the TPA’s methods of analysis and investment strategies. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. The automated investment program involves risks in addition to those described above. Investments in the program are not tailored to individual clients. The program is primarily run by computer, using algorithms established by the investment adviser that runs it. There is a risk that the algorithms, and data input into the algorithms, could have errors that may not easily be detected. There is minimal human involvement in the management of funds in the program. Recommendation of Particular Types of Securities We primarily recommend the following types of securities: mutual funds, exchange traded funds (ETFs), equities, and bonds. You should be advised that investing in these types of securities involves risks including the occurrence of a severe market decline in one or more financial markets, risk of economic contraction or decline and inflation or deflation. When appropriate, we may recommend “no-load” mutual funds to you in order to minimize your costs. Item 9 - Disciplinary Information Neither our firm nor any person affiliated with our firm has any reportable disciplinary information. Item 10 - Other Financial Industry Activities and Affiliations Other Regulatory Registration Neither we nor any of our management personnel is registered or has an application pending to register as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodities pool operator, commodity trading advisor, or an associated person of the foregoing entities. Arrangements with Affiliated Entities Sean M. Dowling, President of our firm, is licensed as an independent insurance agent in New York State. Mr. Dowling has also formed Dowling Financial Group, LLC (“DFG”), 9  which is a licensed insurance agency in Connecticut. Mr. Dowling and DFG earn commission - based compensation for selling insurance products, including insurance products they sell to our clients. Insurance commissions earned by Mr. Dowling and DFG are separate from and in addition to our advisory fees. While Mr. Dowling and DFG try at all times to put the interests of our clients first, this practice presents a conflict of interest because Mr. Dowling and DFG have an incentive to recommend insurance products to clients for the purpose of generating commissions rather than solely based on the client’s needs. However, clients are under no obligation, contractually or otherwise, to purchase insurance products through Mr. Dowling or DFG. Clients are free to purchase insurance products from agents other than Mr. Dowling or DFG. Clients who have engaged our firm for insurance planning services may receive some credit towards the insurance planning fee if they implement our insurance product recommendations through Mr. Dowling or DFG. Sean M. Dowling is also a real estate broker, and he may offer his services as such to our clients. This may present a conflict of interest because Mr. Dowling has an incentive to encourage clients to use his services as a real estate broker for the purpose of generating income for himself rather than solely based on clients’ needs. Moreover, Mr. Dowling’s services may not be the least expensive available. However, clients are free to use any other real estate broker and are under no obligation, contractually or otherwise, to use Mr. Dowling’s real estate broker services. Sean M. Dowling is the owner of Dowling Tax Group, LLC (“DTG”), an income tax preparation firm. If clients require income tax preparation services, we will recommend that they use DTG. Our advisory services are separate and distinct from the compensation paid to DTG for its services. The relationship we have with DTG presents a conflict of interest because we may have a financial incentive to recommend DTG’s services to our clients. While we believe that compensation charged by DTG is competitive, such compensation may be higher than fees charged by other firms providing the same or similar services. Clients are under no obligation to use our affiliates’ services and may obtain comparable services and/or lower fees through other firms. Recommendation of Other Advisers We may recommend that clients use a TPA based on their needs and suitability. 10  Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect clients’ interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing. All of our Associated Persons are expected to adhere strictly to these guidelines. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about clients or their account holdings by persons associated with our firm. Our Code of Ethics is available to clients and prospective clients upon request. You may obtain a copy of our Code of Ethics by contacting Sean M. Dowling at (203) 967-2231. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our Associated Persons nor we shall have priority over your account in the purchase or sale of securities. Item 12 - Brokerage Practices Research and Other Soft Dollar Benefits We do not receive or use any soft dollar benefits from Fidelity, Schwab or any other broker. We do not direct client transactions to a particular broker-dealer in return for soft dollar benefits we receive. Brokerage for Client Referrals Neither we nor any person related to us receives client referrals from a broker-dealer or third party. Directed Brokerage 11  We do not require that any clients direct us to execute transactions through a specified broker-dealer. In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent our firm from effectively negotiating brokerage commissions on your behalf. This practice may also prevent our firm from obtaining the most favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Factors in Choosing Brokers In determining which broker to recommend to our clients, we consider a number of factors to determine which broker will provide the best services at the lowest commission rates possible. We recommend the brokerage and custodial services of Fidelity Brokerage Services, LLC (“Fidelity”), a n d S c h w a b a securities broker-dealer and a member of the New York Stock Exchange and the Securities Investor Protection Corporation. We believe that Fidelity provides quality execution services for you at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by Fidelity, including the value of research provided, the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of research services and additional brokerage products and services Fidelity provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Fidelity provides research services and other benefits to us regardless of the amount of business we do with them. Aggregation of Orders We do not combine multiple orders for shares of the same securities purchased for advisory accounts we manage (the practice of combining multiple orders for shares of the same securities is commonly referred to as “block trading”). Accordingly, you may pay different prices for the same securities transactions than other clients pay. Furthermore, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than other clients. 12  Item 13 - Review of Accounts Portfolio Management Services If you retain our portfolio management services, Sean M. Dowling, President, will monitor your accounts on an ongoing basis and will conduct account reviews at least quarterly and upon your request to ensure that the advisory services provided to you are consistent with your stated investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: • • • • • Contributions and withdrawals; Year-end tax planning; Market moving events; Security specific events; and/or, Changes in your risk/return objectives. We will not provide you with additional or regular written reports in conjunction with account reviews. However, you will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Financial Planning Services We will review your financial plan upon your request to ensure that the recommendations made to you are consistent with your current investment needs and objectives. Written updates to the financial plan may be provided in conjunction with the review. Such reviews and updates will be subject to our then current hourly rate. We will not provide regular written reports to you for financial planning and consulting services. If you implement financial planning advice through our firm, you will receive trade confirmations and monthly or quarterly statements from relevant custodians. Third Party Advisors At your request, we may meet with you and/or your third-party money manager(s) to discuss asset allocation, but we will not make recommendations regarding specific investments or provide any regular written reports to you. Item 14 - Client Referrals and Other Compensation No one other than clients provides an economic benefit to us for providing investment advice or other advisory services to our clients. At this time, we do not compensate any individual or firm for client referrals. However, we may in the future use solicitors for client referrals. If we do use solicitors in the 13  future, we will comply with all applicable laws and regulations and will enter into a written agreement between us and any solicitor. Item 15 - Custody We directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent qualified custodian. You will receive account statements from the independent qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. We will also send you an invoice itemizing the fee, as we intend to use the safeguards described in paragraph 3(f) of the Order of the Connecticut Department of Banking, Securities Division dated February 4, 2005. Sean Dowling and Joseph Dowling occasionally act as trustee for clients, and in those situations, we are deemed to have custody of the assets in the trust. For those accounts, in addition to the safeguards described in the previous paragraph, an annual surprise audit is performed by an accountant, in compliance with the requirements of the Connecticut Department of Banking. Item 16 - Investment Discretion We will manage accounts on either a discretionary or non-discretionary basis, depending upon our agreement with you. If we have discretionary authority to manage your accounts, we will obtain a limited power of attorney from you in addition to the agreement between us. Clients may impose restrictions on our authority to trade in client accounts. For example, you may ask us to avoid certain industries or companies as investment targets, or you may prefer more conservative or long-range investments over short-term gains. Item 17 - Voting Client Securities Proxy Voting We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we 14  would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward to you any electronic solicitation to vote proxies. Item 18 - Financial Information We are not required to provide financial information to our clients because we do not require the prepayment of more than $1200 in fees six or more months in advance. We have custody (but not physical custody) of the cash or securities of a few clients, in our capacity as trustee. We have discretionary authority over some of our client’s assets under our management. We have no financial condition that is reasonably likely to impair our ability to meet our commitments to our clients. We have not been the subject of a bankruptcy petition in the past ten years. Additional Information Your Privacy We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. We do not disclose any nonpublic personal information about you to any nonaffiliated third parties, except as permitted by law. In the course of servicing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys. We restrict internal access to nonpublic personal information about you to employees who need that information in order to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your nonpublic personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or is required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please contact Sean M. Dowling at (203) 967-2231 if you have any questions regarding this policy. Trade Errors 15 ACTIVE/78603.1/KWACKERMAN/10971252v1  In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. If a trade error results in a profit, the trade error will be corrected in the trade error account of the executing broker-dealer and you will not keep the profit. 16 ACTIVE/78603.1/KWACKERMAN/10971252v1