SACKS & ASSOCIATES, LLC

Item 1. Cover Page SACKS & ASSOCIATES, LLC Form ADV, Part 2 Firm Brochure 1160 Route 22 East Bridgewater, New Jersey 08807 P: 908-864-4950 Contact Person: Neil Sacks, Chief Compliance Officer www.sacks-associates.com Date of Brochure: 03/17/2025 This brochure provides information about the qualifications and business practices of Sacks & Associates, LLC. If you have any questions about the contents of this brochure, please contact us at 908-864-4950. 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 Sacks & Associates, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 of 16  Item 2. Material Changes There are no material changes in this brochure from the last annual updating amendment on February 16, 2024 of Sacks & Associates, LLC. Material changes relate to Sacks & Associates, LLC’s policies, practices or conflicts of interest. Page 2 of 16  Item 3. Table of Contents Item 1. Cover Page .......................................................................................................................... 1 Item 2. Material Changes ................................................................................................................ 2 Item 3. Table of Contents................................................................................................................ 3 Item 4. Advisory Business .............................................................................................................. 4 Item 5. Fees and Compensation ...................................................................................................... 5 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 . 10 Item 12. Brokerage Practices ........................................................................................................ 11 Item 13. Review of Accounts........................................................................................................ 14 Item 14. Client Referrals and Other Compensation ...................................................................... 14 Item 15. Custody ........................................................................................................................... 15 Item 16. Investment Discretion ..................................................................................................... 15 Item 17. Voting Client Securities.................................................................................................. 16 Item 18. Financial Information ..................................................................................................... 16 Page 3 of 16  Item 4. Advisory Business The Firm and its Owners. Sacks & Associates, LLC (the “Company” or the “Firm”), was formed in October 2008. The Company was initially registered as an investment adviser with the United States Securities and Exchange Commission in February 2015. The Company’s sole Member is Neil Sacks, who also serves as the Company’s Chief Compliance Officer. The Firm’s Services. As discussed below in this Disclosure Brochure, the Company offers discretionary investment management services and financial and retirement planning as part of its discretionary investment management service platform. The Firm may also offer non-discretionary investment management services. The Company’s investment management services are defined as giving ongoing and continuous investment advice to a client based on the client’s investment objectives and financial situation. During a series of personal meetings with the client, the Company, in conjunction with the client, will ascertain the client’s financial situation, risk tolerance, and investment objectives, developing a retirement plan that will establish general parameters for the Company’s investment management services. After the client agrees with the proposed retirement plan, the Firm will implement the retirement plan over a series of meetings between the Firm and the client. After implementation of the retirement plan, the Firm will monitor the allocations within the client’s account on an ongoing basis. The Company provides investment advice primarily with respect to various equity securities (such as exchange-listed, securities traded over-the-counter, and foreign issuers), exchange traded funds, warrants, corporate debt securities, certificates of deposit, and mutual fund shares. Although the Company’s investment advice is typically limited to those investment categories, the Company may provide advice with respect to other investment opportunities in response to a client request or where the Company determines that it would be in the interests of the client to pursue those other investment opportunities. Where the Firm provides non-discretionary investment management services, the Firm would not be authorized to implement its recommendations for the client’s account without prior authorization from the client; provided, however, that if the client accepts those recommendations, then the Company will have the obligation to so implement such recommendation unless otherwise agreed upon by the client and the Company. During the process of developing the client’s retirement plan, the Company engages in financial and retirement planning, which includes considerations among the areas of insurance planning (including life insurance and annuities), investment and estate planning. These financial and retirement planning services are considered to be elements of the Company’s investment management process. If requested by the client, the Company may assist the client with the implementation of various elements of the Company’s services. The Company may also recommend the services of other professionals if asked by the client. The client is under no Page 4 of 16  obligation to engage the services of any such recommended professional, and retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Company. Miscellaneous Information About the Firm’s Services. In connection with the provision of the Company’s services, (1) the Company tailors its advisory services to the client’s individual needs, (2) clients may impose reasonable restrictions on the Company’s services, which may include restrictions on investing in certain securities or types of securities, (3) the client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from the Company, (4) the Company is authorized to rely on any and all information that is provided to the Company by the client or any of the client’s other professionals (such as the client’s attorney or accountant), and shall not be required to independently verify any such information, and (5) each client is responsible to promptly notify the Company if there is ever any change in their financial situation or investment objectives so that the Company is positioned to review, evaluate and possibly revise its previous recommendations and/or services. Wrap Program. The Company sponsors its own wrap fee program, the details of which are set out in Appendix 1 to this Schedule 2A of Form ADV (the “Wrap Program Brochure”). The Company does not manage wrap fee accounts differently from non-wrap fee accounts, except those clients who are enrolled in the Company’s wrap fee program are charged one bundled fee as set forth in the Wrap Program Brochure. The Company receives a portion of the wrap fee for its services. The Firm’s Assets Under Management. The firm’s investment management services include discretionary and non-discretionary asset management. As of December 31, 2024, the Company had $161,585,555.00 in assets under management on a discretionary basis, and $34,549,581.00 on a non-discretionary basis. Item 5. Fees and Compensation The Firm’s Fees and Compensation for Services. The annual fee for investment management services will be charged as a percentage of assets under management, according to the schedule below: Annual Fee 1.25% 1.00% .90% .80% .75% Assets Under Management Up to $1,000,000 $1,000,000 up to $2,000,000 $2,000,000 up to $4,000,000 $4,000,000 up to $5,000,000 Above $5,000,000 Page 5 of 16  Clients will be invoiced in advance at the end of each calendar quarter based upon the quarter end market value of the assets in the client’s account as of the last business day of the previous quarter. For clients with multiple accounts, the Company, in its sole discretion, may combine the amount of assets in more than one account in determining the fee to be charged to that client for services on the client’s total amount of assets. The Company, in its sole discretion, may charge a different management fee based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, type of services required, account composition, negotiations with client, etc.). In the event of termination of the Company’s services before the end of a billing period for which the Firm received a pre-paid fee, the Firm shall pro-rate its fee through the date of termination and promptly return any unearned portion of that pre-paid fee to the client. Compensation for the Sale of Insurance Products and Annuities Certain of the Company’s personnel are also licensed insurance producers/agents with several insurance companies in various states. In such a capacity , each such personnel may recommend the purchase of certain insurance or annuity products where they will receive a share of revenue derived from the sale of such insurance or annuity products. For further discussion concerning these activities, see Item 10.A of this Disclosure Brochure. The activity disclosed in Item 5.B.1 above represent a conflict of interest and gives the Company personnel engaging in such insurance activities an incentive to recommend the purchase of insurance or annuity products for a client account based on their ability to receive compensation from such a purchase, rather than based on a client’s needs. However, the Firm addresses this conflict by (a) requiring that any such transaction be on commercially reasonable terms that are generally consistent with industry standards, and (b) neither requiring nor expecting that a client will purchase any such insurance or annuity products from or through Firm personnel. In addition, any such Firm personnel must maintain compliance with applicable rules and regulations that govern the sale of such insurance or annuity products. Clients have the option to purchase investment or annuity products that the Company recommends through other brokers or agents that are not affiliated with the Company. The Company’s advisory fee is in addition to any commission that Company personnel may receive and the Company will not reduce its advisory fee to offset such commission. The Company does not charge advisory fees on the value of the insurance or annuity contract after it has been purchased by Firm personnel. General Information on Fees. All fees are negotiable. The Company’s fees shall be deducted from the client’s account by the client’s account custodian. With respect to the Company’s investment management services, the client will also incur charges imposed directly by the custodian of the client’s account, transaction charges imposed by the broker-dealer executing securities transactions for the client’s account, and fees and expenses imposed directly by mutual funds held in or for the client’s account. For further discussion Page 6 of 16  concerning the Company’s brokerage practices, please see Item 12 of this Disclosure Brochure. All fees paid to the Company for its services are separate and distinct from the fees and expenses charged directly by the client’s custodian, the broker-dealer, and mutual funds. The fees and expenses imposed by mutual funds are described in each fund’s prospectus, and will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. The client should review both the fees charged by the funds and the fees charged by the Company to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. We charge an hourly rate for our financial advice. The hourly fee for Neil Sacks is $400 and supporting staff fee is $250 per hour. We require a retainer of fifty percent (50%) of the estimated total financial advice or consulting fee with the remainder of the fee directly billed to you and due to us within thirty days of your retirement plan being delivered or consultation being rendered to you. Item 6. Performance-Based Fees and Side-By-Side Management The company does not charge performance-based fees. Item 7. Types of Clients The Firm’s Clients. The firm’s client base is comprised of individuals, high net worth individuals, and corporations or other business entities. Requirements for Opening or Maintaining an Account. Advisory Agreement. Each client will be required to sign a servicing agreement with the Company that sets forth the terms and conditions of their relationship with the Company. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies. Methods of Analysis. In connection with servicing client accounts, the firm utilizes the following methods of analysis: (a) charting, (b) fundamental, and (c) technical. The main sources of the information that the firm’s personnel use in their investment decision-making process include financial newspapers and magazines, research materials prepared by others, corporate rating services, company press releases, and annual reports, prospectuses, filings with the Securities and Exchange Commission. Investment Strategy. The firm utilizes long term purchases for servicing client accounts. Long term purchases are generally securities that are held at least one year after the date of their purchase. This investment strategy involves various risks, including market risk, liquidity risks and other risks that are associated with investing in the market in general. Page 7 of 16  Risk of Loss. Investing in securities involves risk of loss that each client should be prepared to bear. Security related risks. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic environments. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond (fixed income) nature or stock (equity) nature, or a mix of multiple underlying security types. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Because ETFs use "authorized participants" (APs) as agents to facilitate creations or redemptions (primary market), there is a risk that an AP decides to no longer participate for a particular ETF; however, that risk is mitigated by the fact that other APs can step in to fill the vacancy of the withdrawing AP [an ETF typically has multiple APs] and ETF transactions predominantly take place in the secondary market without need for an AP. Like other liquid securities, ETF pricing changes throughout the trading day and there can be no guarantee that an ETF is purchased at the optimal time in terms of market movements. Moreover, due to market fluctuations, ETF brokerage costs, differing demand and characteristics of underlying securities, and other factors, the price of an ETF can be lower that the aggregate market price of its cash and component individual securities (net asset value – NAV). An ETF is subject to the same market risks as those of its underlying individual securities, and also has internal expenses that can lower investment returns. Fixed Income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This includes corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general the fixed income market is volatile, and fixed income securities carry significant interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting, but these bonds still carry a risk of losing share price value. Risks of investing in foreign fixed income securities also include the general risks inherent in non-U.S. investing. Annuities are retirement products for those who may have the ability to pay a premium now and want to guarantee they receive certain payments or a return on investment in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long term Page 8 of 16  goals. An annuity is not a life insurance policy. Variable annuities are designed to be long term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9. Disciplinary Information The Firm does not have any information to disclose in response to this Item. Item 10. Other Financial Industry Activities and Affiliations Other Registrations. As mentioned in the discussion to Item 5.B of this Disclosure Brochure, certain of the Firm’s personnel (including the Firm’s sole Member and Chief Compliance Officer Neil Sacks) are also licensed insurance producers/agents with various insurance companies in various states. In such capacity, each such individual may recommend the purchase of certain insurance or annuity products where they will receive a share of revenue derived from the sale of such insurance or annuity products. This activity represents a conflict of interest and gives Firm personnel an incentive to recommend the purchase of insurance or annuity products for a client account based on their ability to receive compensation from such a purchase, rather than based on a client’s needs. However, the Firm seeks to address this conflict by (a) requiring that any such transaction will be on commercially reasonable terms that are generally consistent with industry standards, and (b) neither requiring nor expecting that a client will purchase any such insurance or annuity products from or through Firm personnel. In addition, Firm personnel must comply with applicable rules and regulations that govern the sale of such products. Clients have the option to purchase investment products that the Firm recommends through other brokers or agents that are not affiliated with the Firm. Other Financial Industry Activities. See the discussion in Item 10.A (“Other Registrations”) of this Disclosure Brochure discussing the registrations held by certain Firm personnel. When Firm personnel act in the capacity of insurance producers/agents they will engage in other financial industry activities that are commensurate with such other registrations. Other Financial Industry Affiliations. Please see the response in this Disclosure Brochure to Item 10.A above (“Other Registrations”). Page 9 of 16  Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of the Firm’s Code of Ethics The Company has adopted a Code of Ethics pursuant to SEC Rule 204A-1, which serves to establish a standard of business conduct for all of the firm’s personnel that is based upon fundamental principles of openness, integrity, honesty and trust. The Company is a fiduciary and therefore has the responsibility to render professional, continuous, and unbiased investment advice. As a fiduciary, the Company must act at all times in its clients’ best interest and must avoid or disclose conflicts of interest. It is the purpose of the Company’s Code of Ethics to emphasize and implement these fundamental principles within its operations. Information concerning the identity of security holdings and financial circumstances of clients is to be confidential. Failure to comply with the Code of Ethics may result in disciplinary action, which may include termination of employment. The Company will provide a copy of the Code of Ethics to any client or prospective client upon request. Investing by the Firm and its Personnel The purchase or sale of the same securities as for the client. The Company and Company personnel may purchase, sell or hold the same securities for each of its and their own accounts as are purchased or sold for client accounts. In addition, any person affiliated with the Company may directly or indirectly hold the same securities as the Company recommends to clients. These investment activities present a conflict of interest in the sense that the Company, or its personnel, may benefit financially from a transaction effected for a client account. The firm believes that it has addressed this conflict of interest through its internal compliance policies. Initially, each such person will be required to report to the Chief Compliance Officer of the Company all securities transactions during the preceding quarter in which she or he had a direct or indirect beneficial interest, and the Chief Compliance Officer will be required to report his securities transactions to other Firm personnel. Next, employees, officers and directors of the Company are prohibited from using any information acquired in their capacities as such to affect any trade or undertake any activity that may adversely affect the Company’s clients or their interests. All are similarly prohibited from furnishing such information to others or otherwise improperly using such information for their own benefit. Further, the Company emphasizes the overarching right of the client to decline to implement any advice rendered. Lastly, the Company requires that all personnel act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Any individual not in observance of the above may be subject to termination. The purchase or sale of the same securities at or about the same time as in a client’s account. The Company, and/or any person related to the Company, may recommend securities to clients, or buy or sell securities for client accounts, at or about the same time that the Company or the person related to the Company buys or sells the same securities for the account of the Company or the Company’s related person. This presents a conflict of interest because the Company or the related person may benefit financially as a result of transactions in that same security that occur in the Page 10 of 16  client account. Similarly, the value of the security held in the client’s account may be detrimentally impacted by transactions in that same security that occur in the Company’s account or the account of the Company’s related person. The firm believes that it has addressed this conflict of interest through its internal compliance policies as described in Item 11. B.1. Item 12. Brokerage Practices Factors the Firm Considers in Selecting a Broker-Dealer. Selection Criteria. In placing orders for the purchase and sale of securities and selecting brokers to effect these transactions, the Company will utilize broker-dealers that it reasonably believes will provide “best execution”. In seeking “best execution”, the determinative factor is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution. The Company will seek prompt execution of orders at the most favorable prices reasonably obtainable under the circumstances. In doing so, the Company will consider a number of factors including, without limitation, execution capability, commission rates, and responsiveness. The Company will weigh the amount of the broker’s compensation against the other criteria it considers in selecting the broker to execute client securities transactions to determine whether the broker’s compensation is reasonable in light of those other factors. Accordingly, although the Company will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for account transactions. The firm recommends Charles Schwab & Co., Inc. Advisor Services. Research and other soft dollar benefits. Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, the Company may take into consideration the investment research services that are available from a broker-dealer when determining whether to execute through that broker-dealer. However, the Company anticipates that the Company’s ability to obtain investment research services from the broker as a result of the Company executing client securities transactions through such brokers will be utilized primarily to benefit client portfolios. Such research generally will be used to service all of the Company’s clients, but brokerage commissions paid by a client may be used to pay for research that is not used in managing the client’s account and may in fact benefit a client who did not pay for the use of that research. Except as indicated above, the Company’s clients may pay more for investment transactions effected and/or assets maintained at a particular broker-dealer or custodian as a result of this arrangement. Further, and except as indicated above, there is no corresponding commitment made by the Company to any other entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as result of the above arrangement. The foregoing represents a conflict of interest. When the Company uses client brokerage commissions to obtain research or other products or services, the Company receives a benefit because the Company does not have to produce or pay for the research, products or services. The Page 11 of 16  Company has an incentive to select or recommend a broker-dealer based on the Company’s interest in receiving the research or other products of services, rather than on the client’s interest in receiving most favorable execution. It is possible that clients may pay higher commission costs due to the Company’s use of that research, or those products or services. The Firm's receipt of any of the foregoing items does not diminish the Firm's duty to act in the best interests of its clients, including to seek best execution of trades for client accounts. During this fiscal year, the Company anticipates acquiring products and services with client brokerage commissions consistent with the above disclosure. Nonetheless, we anticipate that the products and services the Firm will receive will generally be available to other investment advisers in a similar position as the Firm. We do not believe that the receipt of the items mentioned in Section 12.A.2 compromise our ability to service our clients in an unbiased manner and will not prevent use from changing the broker-dealer/custodian if we believe that a different broker- dealer/custodian would provide better execution and custodial services taking into consideration all of the direct and indirect benefits to the client from use that custodian. Charles Schwab & Co., Inc. Advisor Services provides the Firm with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For the Firm’s client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of the Firm by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist the Firm in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of the Firm’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some Page 12 of 16  substantial number of the Firm’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to the Firm other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to the Firm. The Firm is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. Please also see the discussion within Item 14 to this Disclosure Brochure. Directed brokerage. The Company does not recommend, request or require that a client direct it to execute transaction through a specified broker-dealer. Nonetheless, the Company may permit a client to request that the Company effect securities transaction for that client’s account through a particular broker- dealer. A client’s direction of brokerage can limit or eliminate the Company’s ability to negotiate commissions (which could result in higher commission costs) and otherwise obtain most favorable execution of client transactions. In addition, the Company may be unable to aggregate orders to reduce transaction costs. If the client directs brokerage, the client will negotiate terms and arrangements for the account with that broker-dealer, and the Company will not seek better execution services or prices from other broker-dealers. As a result, the client may pay higher commissions or other transaction costs or incur greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. In other words, directing brokerage may cost a client more money. No Company client is required to implement the Company’s investment recommendations through, or purchase and/or sell insurance, from or through any of the Company’s personnel in their separate capacities as insurance agents. Aggregation. Transactions for each client account generally will be effected independently, unless Registrant decides to purchase or sell the same securities for several clients at approximately the same time. Registrant may (but is not obligated to) combine or "batch" such orders to obtain “best execution”, to negotiate more favorable commission rates, or to allocate equitably among Registrant’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among Registrant's clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that Registrant determines to aggregate client orders for the purchase or sale of securities, including securities in which Registrant's principals and/or associated persons may invest, Registrant shall generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Incorporated. Registrant shall not receive any additional compensation or remuneration as a result of the Page 13 of 16  aggregation. In the event that the Firm elects not to aggregate or batch client securities transactions when it has the opportunity to do so, the client may receive a higher price per transaction than if the Firm had aggregated the subject transaction. Item 13. Review of Accounts Account Reviews. The Company will review accounts periodically. Each client account will be monitored by that client’s adviser, and reviewed whenever significant economic events, changes in market conditions or important new developments concerning a security affect any individual account. If warranted, Firm personnel will take appropriate action consistent with the goals and objectives of each account. Account Reports. Clients will receive a written retirement plan from the Firm and confirmations of all transactions from broker-dealers on a monthly basis for securities transactions. In addition, the Firm will provide a net worth statement to each client. Item 14. Client Referrals and Other Compensation Non-Clients providing an Economic Benefit to the Company. Charles Schwab & Co., Inc. Advisor Services provides the Firm with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For the Firm’s client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of the Firm by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist the Firm in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client Page 14 of 16  account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of the Firm’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to the Firm other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to the Firm. The Firm is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. Compensation paid for client referrals. The Company may compensate third parties for client referrals pursuant to a written agreement between the Company and such third party where the Company pays the third party a portion of the compensation that is paid to the Company. Where a client is referred to the Company under such an arrangement, the client shall receive a separate disclosure statement that identifies the referring party and the Company, describes the nature of the relationship between the referring party and the Company, discloses both that the referring party will be compensated for the referral and the terms of that compensation, and the amount, if any, for the cost of obtaining the referred client that the client will be charged in addition to the Company’s advisory fee, and the differential, if any, among clients with respect to the amount or level of advisory fees charged by the Company if such differential is attributable to the existence of any arrangement pursuant to which the Company has agreed to compensate the referring party for referring clients for, or referring clients to, the Company. Item 15. Custody The client’s assets are maintained with a qualified custodian Charles Schwab & Co., Inc. Advisor Services. The qualified custodian is authorized by the client to deduct and direct payment of the Company’s advisory fee directly from the client’s custodial account. Each client will receive account statements directly from the broker on at least a quarterly basis. Each client should carefully review those statements. In the event that a client also receives an account statement from the Company, each client is urged to compare the account statement they receive from the qualified custodian with the account statement they receive from the Company, and to rely solely on the account statement received from the qualified custodian. Item 16. Investment Discretion It is expected that the majority of the activities of the Company will involve individual investment advice provided to individual clients. Generally, this advice will be discretionary, which means Page 15 of 16  that Sacks will be authorized to determine the securities and the amount of such securities to be bought or sold for the client’s account(s). Nonetheless, Sacks, in response to a client request, or where it determines necessary, will communicate its investment recommendations and advice to its clients prior to seeking to implement that recommendation and/or advice. Each client may request reasonable limitations be placed on Sacks’ discretionary authority, such as securities- based limitations. Any such limitations shall be presented to the Company for consideration in writing, and clients may change/amend those limitations, in writing, as the client requires. The client’s written agreement with the Company may grant discretionary authority to the Company. The client’s written agreement with the custodian also grants a limited power of attorney to the Company relative to transactions in the client’s custodial account. Where Sacks does not have discretionary investment management authority, Sacks may still have discretionary trading authority under the client’s agreement with the client’s account custodian. Item 17. Voting Client Securities The Company does not vote client proxies for client accounts. Therefore, although the Company may provide investment advisory services relative to client investment assets, the Company’s clients maintain exclusive responsibility for (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings and other type events pertaining to the client’s investment assets. The Company and/or the client shall correspondingly instruct each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. The Company generally does not advise clients on questions regarding a particular solicitation. Item 18. Financial Information As an advisory firm that maintains discretionary authority for client accounts and custody of client funds, we are also required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. Sacks has no additional financial circumstances to report and has never been the subject of a bankruptcy petition. Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to provide a balance sheet. Page 16 of 16 

Item 1: Cover Page SACKS & ASSOCIATES, LLC Form ADV, Part 2A Appendix 1 Wrap Fee Program Brochure 1160 Route 22 East Bridgewater, New Jersey 08807 P: 908-864-4950 Contact Person: Neil Sacks, Chief Compliance Officer www.sacks-associates.com Date of Brochure: March 17, 2025 This wrap fee program brochure provides information about the qualifications and business practices of Sacks & Associates, LLC. If you have any questions about the contents of this brochure, please contact us at 908-864-4950. 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 Sacks & Associates, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Registration as an investment adviser, or any reference to the firm being or the use of the term “registered”, “registration” or “registered investment adviser” does not imply a certain level of skill or training. Page 1 of 15  Item 2: Material Changes There are no material changes in this brochure from the last annual updating amendment to this Wrap Fee Program Brochure on February 16, 2024. Material changes relate to Sacks & Associates, LLC's policies, practices or conflicts of interest. Page 2 of 15  Table of Contents Item 1: Cover Page.......................................................................................................................... 1 Item 2: Material Changes ............................................................................................................... 2 Table of Contents ............................................................................................................................ 3 Item 3: Services, Fees and Compensation ...................................................................................... 4 A. Service. ........................................................................................................................... 4 B. Fees and Compensation. ................................................................................................. 8 C. Compensation for the Sale of Insurance Products and Annuities ................................ 10 D. Miscellaneous............................................................................................................... 11 Item 4: Account Requirements and Types of Clients ................................................................... 11 A. Account Requirements. ................................................................................................ 11 B. Types of Clients ........................................................................................................... 11 Item 5: Portfolio Manager Selection and Evaluation .................................................................... 12 A. Sacks as Portfolio Manager in Program ....................................................................... 12 Item 6: Client Information Provided to Portfolio Managers ......................................................... 12 Item 7: Client Contact with Portfolio Managers ........................................................................... 12 Item 8: Additional Information ..................................................................................................... 12 A. Discpilinary Information .............................................................................................. 12 B. Other Financial Industry Activities and Affiliations .................................................... 12 C. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. ................................................................................................................. 13 D. Review of Accounts; Reporting ................................................................................... 14 E. Client Referrals and Other Compensation .................................................................... 14 F. Financial Information ................................................................................................... 15 Page 3 of 15  Item 3: Services, Fees and Compensation A. Service. 1. Description of Wrap Fee Program. As discussed in this Wrap Fee Program Brochure, Sacks & Associates, LLC (“Sacks”, the “Firm”, or the “Company”) offers discretionary and non-discretionary investment management services on a wrap fee basis. The wrap fee program (the “Program”) is designed so as to bundle investment advisory, brokerage and custody services into one single fee that a client will incur. Sacks is the sponsor of and portfolio manager (the “Portfolio Manager”) in the Program. As Portfolio Manager, Sacks provides discretionary investment management services to Program clients for a single annual fee (the “Program Fee”). The Program Fee includes charges and fees relative to (a) execution of client securities transactions, (b) custody, (c) investment management, and (d) reporting on the client’s account, but does not include those items described in Section 4.B.5 or compensation associated with the activities indicated in Section 4.C.1 and 4.D.1 below. The Program does not include separate financial planning or consulting services. 2. Sacks’s Investment Management Services Under the Program. As discussed below in this Wrap Fee Program Brochure, the Company offers discretionary investment management services and financial and retirement planning as part of its discretionary investment management service platform. The Firm may also offer non- discretionary investment management services. The Company’s investment management services are defined as giving ongoing and continuous investment advice to a client based on the client’s investment objectives and financial situation. During a series of personal meetings with the client, the Company, in conjunction with the client, will ascertain the client’s financial situation, risk tolerance, and investment objectives, developing a retirement plan that will establish general parameters for the Company’s investment management services. After the client agrees with the proposed retirement plan, the Firm will implement the retirement plan over a series of meetings between the Firm and the client. After implementation of the retirement plan, the Firm will monitor the allocations within the client’s account on an ongoing basis. The Company provides investment advice primarily with respect to various equity securities (such as exchange-listed, securities traded over-the-counter, and foreign issuers), exchange traded funds, warrants, corporate debt securities, certificates of deposit, and mutual fund shares. Although the Company’s investment advice is typically limited to those investment categories, the Company may provide advice with respect to other investment opportunities in response to a client request or where the Company determines that it would be in the interests of the client to pursue those other investment opportunities. Page 4 of 15  the client; provided, however, that if the client accepts Where the Firm provides non-discretionary investment management services, the Firm would not be authorized to implement its recommendations for the client’s account without prior authorization from those recommendations, then the Company will have the obligation to so implement such recommendation unless otherwise agreed upon by the client and the Company. During the process of developing the client’s retirement plan, the Company engages in financial and retirement planning, which includes considerations among the areas of insurance planning (including life insurance and annuities), investment and estate planning. These financial and retirement planning services are considered to be elements of the Company’s investment management process. If requested by the client, the Company may assist the client with the implementation of various elements of the Company’s services. The Company may also recommend the services of other professionals if asked by the client. The client is under no obligation to engage the services of any such recommended professional, and retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Company. 3. Methods of Analysis; Investment Strategies. Sacks utilizes fundamental, technical and charting methods of securities analysis. Sacks utilizes a primary investment strategy of long term purchases which are typically those purchases of securities that are held for at least a year. Long term purchases involve various risks, including the loss of principal due to market events. 4. Statements Concerning Risk Each client should understand that investing in securities involves risk of loss that they should be prepared to bear. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Sacks) will be profitable or equal any specific performance level(s). However, every method of analysis has its own inherent risks. To perform an accurate market analysis Sacks must have access to current/new market information. Since Sacks has no control over the dissemination rate of market information, certain analyses may be compiled with outdated market information, severely limiting the value of Sacks’s analysis. Furthermore, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that a forecasted change in market value will materialize into actionable and/or profitable investment opportunities. 5. Custodian Under the Program The client’s assets are maintained with a qualified custodian. Sacks shall generally recommend that Charles Schwab & Co., Inc. Advisor Services serve as the custodian for client investment management assets within the Program. Each client will receive account statements directly from the broker on at least a quarterly basis. Each client should carefully review those statements. In the event that a client also receives an account statement from Sacks, each client is urged to compare the account statement they receive from the qualified custodian with the Page 5 of 15  account statement they receive from Sacks, and to rely solely on the account statement received from the qualified custodian. 6. Broker-Dealer Under the Program (a) Selection Criteria. In placing orders for the purchase and sale of securities and selecting brokers to effect these transactions, the Company will utilize broker-dealers that it In seeking “best execution”, the reasonably believes will provide “best execution”. determinative factor is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution. The Company will seek prompt execution of orders at the most favorable prices reasonably obtainable under the circumstances. In doing so, the Company will consider a number of factors including, without limitation, execution capability, commission rates, and responsiveness. The Company will weigh the amount of the broker’s compensation against the other criteria it considers in selecting the broker to execute client securities transactions to determine whether the broker’s compensation is reasonable in light of those other factors. Accordingly, although the Company will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for account transactions. (b) Discretionary Authority. It is expected that the majority of the activities of the Company will involve individual investment advice provided to individual clients. Generally, this advice will be discretionary, which means that Sacks will be authorized to determine the securities and the amount of such securities to be bought or sold for the client’s account(s). Nonetheless, Sacks, in response to a client request, or where it determines necessary, will communicate its investment recommendations and advice to its clients prior to seeking the implement of that recommendation and/or advice. Each client may request reasonable limitations be placed on Sacks’ discretionary authority, such as securities-based limitations. Any such limitations shall be presented to the Company for consideration in writing, and clients may change/amend those limitations, in writing, as the client requires. The client’s written agreement with the Company may grant discretionary authority to the Company. The client’s written agreement with the custodian also grants a limited power of attorney to the Company relative to transactions in the client’s custodial account. (c) Where Sacks does not have discretionary investment management authority, Sacks may still have discretionary trading authority under the client’s agreement with the client’s account custodian. (d) Research and other soft dollar benefits. Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker- dealer/custodian, the Company may take into consideration the investment research services that are available from a broker-dealer when determining whether to execute through that broker- dealer. However, the Company anticipates that the Company’s ability to obtain investment research services from the broker as a result of the Company executing client securities transactions through such broker will be utilized primarily to benefit client portfolios. Such research generally will be used to service all of the Company’s clients, but brokerage commissions paid Page 6 of 15  by a client may be used to pay for research that is not used in managing the client’s account, and may in fact benefit a client who did not pay for the use of that research. Except as indicated above, the Company’s clients may pay more for investment transactions effected and/or assets maintained at a particular broker-dealer or custodian as a result of this arrangement. Further, and except as indicated above, there is no corresponding commitment made by the Company any other any entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as result of the above arrangement. The foregoing represents a conflict of interest. When the Company uses client brokerage commissions to obtain research or other products or services, the Company receives a benefit because the Company does not have to produce or pay for the research, products or services. The Company has an incentive to select or recommend a broker-dealer based on the Company’s interest in receiving the research or other products of services, rather than on the client’s interest in receiving most favorable execution. It is possible that clients may pay higher commission costs due to the Company’s use of that research, or those products or services. The Firm's receipt of any of the foregoing items does not diminish the Firm's duty to act in the best interests of its clients, including to seek best execution of trades for client accounts. During this fiscal year, the Company anticipates acquiring products and services with client brokerage commissions consistent with the above disclosure. Nonetheless, we anticipate that the products and services the Firm will receive will generally be available to other investment advisers in a similar position as the Firm. We do not believe that the receipt of the items mentioned in Section 4.A.6 compromise our ability to service our clients in an unbiased manner and will not prevent use from changing the broker-dealer/custodian if we believe that a different broker-dealer/custodian would provide better execution and custodial services taking into consideration all of the direct and indirect benefits to the client from use that custodian. Charles Schwab & Co., Inc. Advisor Services provides the Firm with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For the Firm’s client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may Page 7 of 15  include national, regional or Firm specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of the Firm by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist the Firm in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of the Firm’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to the Firm other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to the Firm. The Firm is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. (e) Aggregation. Transactions for each client account generally will be effected independently, unless Sacks decides to purchase or sell the same securities for several clients at approximately the same time. Sacks may (but is not obligated to) combine or "batch" such orders to obtain “best execution”, to negotiate more favorable commission rates, or to allocate equitably among Sacks’s clients differences in prices and commissions that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among Sacks's clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that Sacks determines to aggregate client orders for the purchase or sale of securities, including securities in which Sacks's principals and/or associated persons may invest, Sacks shall generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Incorporated. Sacks shall not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm elects not to aggregate or batch client securities transactions when it has the opportunity to do so, the client may receive a higher price per transaction than if the Firm had aggregated the subject transaction. B. Fees and Compensation. 1. Program Fee The Program Fee shall vary depending upon the market value of the assets under management within the Program and is generally between 1.25% and .75% based on the following schedule: Page 8 of 15  Account Size Annual Fee Portion of Program Fee Payable to Sacks as Portfolio Manager Up to $1,000,000 1.25% 1.25% $1,000,000 up to $2,000,000 1.00% 1.00% $2,000,000 up to $4,000,000 0.90% 0.90% $4,000,000 up to $5,000,000 0.80% 0.80% Above $5,000,000 0.75% 0.75% Sacks may deviate from this fee schedule based based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, type of services required, account composition, negotiations with client, etc.). 2. Program Fee Calculation. The Program Fee shall be calculated as described in Section 4.B.1 above. 3. Performance Based Fees and Side-by-Side Management. No portion of the Program fee shall be based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds within a client’s account. Sacks does not engage in side-by-side management. 4. Program Fee Payment The Program Fee shall be payable quarterly, in advance, at the end of each calendar quarter based upon the quarter end market value of the assets in the clients’ account as of the law business day of the previous quarter. For clients with multiple accounts, the Company, in its sole discretion, may combine the amount of assets in more than one account in determining the fee to be charged to that client for services on the client’s total amount of assets. The Program Fee shall be deducted from the client’s custodial account. Both Sacks's servicing agreement and the custodial/ clearing agreement may authorize the custodian to debit the account for the amount of the Program Fee and to directly remit that Program Fee to Sacks in compliance with regulatory procedures. In the event of termination of the Company’s services before the end of a billing period for which the Firm received a pre-paid fee, the Firm shall pro-rate its fee through the date of termination and promptly return any unearned portion of that pre-paid fee to the client. Page 9 of 15  5. Charges Not Included in Program Fee. The Program Fee does not include (a) transaction charges resulting from trades effected through a broker-dealer other Charles Schwab & Co., Inc. Advisor Services, (b) transfer taxes, (c) odd lot differentials, (d) exchange fees, (e) interest charges, (f) American Depository Receipt agency processing fees, (g) fees and expenses imposed directly by mutual funds held in or for the client’s account, and (h) any charges, taxes or other fees mandated by any governmental entity. The client will incur such additional charges and fees in addition to the Program Fee. 6. Disclosures Concerning the Program Fee. Participation in the Program may cost a client more or less than purchasing each or any collection of the services included in the Program separately. In addition, the Program Fee may be higher or lower than the fee(s) charged by sponsors of other comparable wrap fee programs. Sacks receives compensation as a result of a client’s participation in the Program. The amount of Sacks’s compensation may be more than what Sacks would receive if the client participated in Sacks’s programs or paid separately for investment advice, brokerage, and other services. In other words, depending upon the percentage Program Fee charged by Sacks, the amount of portfolio activity in the client's account, and the value of custodial and other services provided, the Program Fee may or may not exceed the aggregate cost of such services if they were to be provided separately. Therefore, Sacks may have a financial incentive to recommend the Program over other programs or services. C. Compensation for the Sale of Insurance Products and Annuities 1. Certain of the Company’s personnel are also licensed insurance producers/agents with several insurance companies in various states. In such capacity, each such personnel may recommend the purchase of certain insurance or annuity products where they will receive a share of revenue derived from the sale of such insurance or annuity products. For further discussion concerning these activities, see Item 9.B of this Wrap Fee Program Brochure. 2. The activity disclosed in Item 4.C.1 above represent a conflict of interest and gives the Company personnel engaging in such insurance activities an incentive to recommend the purchase of insurance or annuity products for a client account based on their ability to receive compensation from such a purchase, rather than based on a client’s needs. However, the Firm addresses this conflict by (a) requiring that any such transaction be on commercially reasonable terms that are generally consistent with industry standards, and (b) neither requiring nor expecting that a client will purchase any such insurance or annuity products from or through Firm personnel. In addition, any such Firm personnel must maintain compliance with applicable rules and regulations that govern the sale of such insurance or annuity products. 3. Clients have the option to purchase investment or annuity products that the Company recommends through other brokers or agents that are not affiliated with the Company. 4. The Company’s advisory fee is in addition to any commission that Company personnel may receive and the Company will not reduce its advisory fee to offset such commission. The Page 10 of 15  Company does not charge advisory fees on the value of the insurance or annuity contract after it has been purchased by Firm personnel. D. Miscellaneous In connection with the provision of the Company’s services, (1) the Company tailors its advisory services to the client’s individual needs, (2) clients may impose reasonable restrictions on the Company’s services, which may include restrictions on investing in certain securities or types of securities, (3) the client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from the Company, (4) the Company is authorized to rely on any and all information that is provided to the Company by the client or any of the client’s other professionals (such as the client’s attorney or accountant), and shall not be required to independently verify any such information, (5) each client is responsible to promptly notify the Company if there is ever any change in their financial situation or investment objectives so that the Company is positioned to review, evaluate and possibly revise its previous recommendations and/or services, and (6) with respect to the Program Fee, neither Sacks, nor its representatives will receive as compensation for their services, any compensation from the sale of securities or other investment products. With respect to Proxy matters, each client maintains exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients will receive their proxies or other solicitations directly from their custodian. The Company generally does not advise clients on questions regarding a particular solicitation. With respect to trade errors, In the event of a trade error resulting from a client’s account transactions, Sacks shall reimburse accounts for Sacks’s trade errors. Item 4: Account Requirements and Types of Clients A. Account Requirements. 1. Advisory Agreement. Each client will be required to sign a servicing agreement with Sacks that sets forth the terms and conditions of their relationship with Sacks. The servicing agreement may be canceled at any time, by either party, for any reason upon receipt of prior written notice. Upon termination of a client account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. B. Types of Clients 1. The firm’s client base is comprised of individuals, high net worth individuals, corporations and other business entities. Page 11 of 15  Item 5: Portfolio Manager Selection and Evaluation A. Sacks as Portfolio Manager in Program Sacks acts as the Portfolio Manager for the Program. Inasmuch as the execution costs for transactions effected in the client account will be paid by Sacks, a potential conflict of interest arises in that Sacks may have a disincentive to trade securities in the client account. In addition, as described in Section 5 above, the amount of compensation received by Sacks as a result of the client’s participation in the Program may be more than what Sacks would receive if the client paid separately for investment advice, brokerage and other services. Please also see Section 4 of this Wrap Fee Program Brochure that describes Sacks’s advisory business, performance based fees and side-by-side management, methods of analysis, investment strategies and risk of loss, and voting client securities. The Firm’s Assets Under Management. The firm’s investment management services include discretionary and non-discretionary asset management. As of December 31, 2024, the Company had $161,585,555.00 in assets under management on a discretionary basis, and $34,549,581.00 on a non-discretionary basis. Item 6: Client Information Provided to Portfolio Managers Since Sacks is the Program Portfolio Manager, it receives and reviews information from the client directly. Item 7: Client Contact with Portfolio Managers Each client is free to have reasonable access to the Program’s Portfolio Manager. Item 8: Additional Information A. Discpilinary Information Sacks does not have any information that is disclosable under this Item 9. B. Other Financial Industry Activities and Affiliations 1. Other Registrations. (a) Certain of the Firm’s personnel (including the Firm’s sole Member and Chief Compliance Officer Neil Sacks) are also licensed insurance producers/agents with various insurance companies in various states. In such capacity, each such individual may recommend the purchase of certain insurance or annuity products where they will receive a share of revenue derived from the sale of such insurance or annuity products. This activity represents a conflict of interest and gives Firm personnel an incentive to recommend the purchase of insurance or annuity products for a client account based on their ability to receive compensation from such a Page 12 of 15  purchase, rather than based on a client’s needs. However, the Firm seeks to address this conflict by (a) requiring that any such transaction will be on commercially reasonable terms that are generally consistent with industry standards, and (b) neither requiring nor expecting that a client will purchase any such insurance or annuity products from or through Firm personnel. In addition, Firm personnel must comply with applicable rules and regulations that govern the sale of such products. Clients have the option to purchase investment products that the Firm recommends through other brokers or agents that are not affiliated with the Firm. 2. Other Financial Industry Activities. See the discussion in Item 9.B.1 (“Other Registrations”) of this Wrap Fee Program Brochure discussing the registrations held by certain Firm personnel. When Firm personnel act in the capacity of insurance producers/agents they will engage in other financial industry activities that are commensurate with such other registrations. 3. Other Financial Industry Affiliations. Please see the response in this Wrap Fee Program Brochure to Item 9.B.1 above (“Other Registrations”). C. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. 1. Sacks maintains an investment policy relative to personal securities transactions. This investment policy is part of Sacks’s overall Code of Ethics, which serves to establish a standard of business conduct for all of Sacks’s representatives that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request. In accordance with Section 204A of the Investment Advisers Act of 1940, Sacks also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by Sacks or any person associated with Sacks. 2. Neither Sacks nor any related person of Sacks recommends, buys, or sells for client accounts, securities in which Sacks or any related person of Sacks has a material financial interest. 3. Sacks and/or representatives of Sacks may buy or sell securities that are also recommended to clients. This practice may create a situation where Sacks and/or representatives of Sacks are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that security for investment and then immediately sells it at a profit upon the rise in the market price which follows the recommendation) could take place if Sacks did not have adequate policies in place to detect such activities. In addition, this requirement can help detect insider trading, “front-running” (i.e., personal trades executed prior to those of Sacks’s clients) and other potentially abusive practices. Sacks has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of Sacks’s “Access Persons”. Sacks’s securities transaction policy requires that an Access Person of Sacks must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten Page 13 of 15  (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person’s current securities holdings at least once each twelve (12) month period thereafter on a date Sacks selects; provided, however that at any time that Sacks has only one Access Person, he or she shall not be required to submit any securities report described above. 4. Sacks and/or representatives of Sacks may buy or sell securities, at or around the same time as those securities are recommended to clients. This practice creates a situation where Sacks and/or representatives of Sacks are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. As indicated above, Sacks has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of Sacks’s Access Persons. D. Review of Accounts; Reporting 1. Account Reviews. The Company will review accounts periodically. Each client account will be monitored by that client’s adviser, and reviewed whenever significant economic events, changes in market conditions or important new developments concerning a security affect any individual account. If warranted, Firm personnel will take appropriate action consistent with the goals and objectives of each account. 2. Account Reports. Clients will receive a written retirement plan from the Firm and confirmations of all transactions from broker-dealers on a monthly basis for securities transactions. In addition, the Firm will provide a net worth statement to each client. E. Client Referrals and Other Compensation 1. Research and Other Benefits. See the discussion in this Wrap Program Brochure to benefits received by the Company from the broker in connection with execution of client securities transactions. Charles Schwab & Co., Inc. Advisor Services provides the Firm with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For the Firm’s client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are Page 14 of 15  executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of the Firm by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist the Firm in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of the Firm’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to the Firm other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to the Firm. The Firm is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. F. Financial Information 1. Sacks does not solicit fees of more than $1,200, per client, six months or more in advance. 2. Sacks is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts. 3. Sacks has not been the subject of a bankruptcy petition. Page 15 of 15