Stony Point Wealth Management Inc. d/b/a Seneca House Advisors (“Seneca” or the “Firm”) has been in business since May of 2015. Matthew Daniel and Elizabeth King are the Firm’s principal owners. Together, the owners have been in the financial services industry for over 50 years. Since March 2018, Elizabeth King has served as Chief Compliance Officer. Seneca provides personalized asset management, portfolio monitoring and financial planning services. All available services may be offered together or on an individualized basis at the client’s discretion. The Firm provides investment advice to individuals, families, trusts, charitable organizations and foundations, pensions, and corporations. The Firm also serves as investment manager to an affiliated private fund, SHA Realty Partners Fund I, LLC. We believe that working with multiple generations of the same family can enhance the depth to which we understand a client and their financial situation. As such, we encourage multi-generational families to align their goals, but the potential for conflicts of interest exist with the exchange of intergenerational information. Seneca attempts to minimize these conflicts by treating each household as its own fiduciary relationship. Information can only be shared across generations with each household’s consent. Seneca strives to provide clients with a high level of individual attention by getting to know the client and tailoring the services to their needs. Wealth should continue to build steadily over time, and Seneca’s view is that steady growth over a period of years will be more beneficial to clients than shooting for unattainable returns year after year. We look at a client’s entire financial picture, ask targeted questions and listen closely to your answers. Our goal is for you to experience financial confidence now and in retirement. Asset Management Services Asset Management Services may be provided on a “discretionary” or on a “non-discretionary” basis. When Seneca is engaged to provide these services on a discretionary basis, we will recommend personalized asset allocation services as well as provide continuous monitoring of your accounts. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Advisory Agreement that outlines the responsibilities of both the client and Seneca. When consistent with the client’s risk tolerance and investment objectives, we may also recommend investment in private investment vehicles, including one or more affiliated private funds. Private investment recommendations are provided on a non-discretionary basis only, even in otherwise discretionary Asset Management engagements. When a client engages us to provide Asset Management Services on a non-discretionary basis, we monitor the accounts in the same way as for discretionary services. However, Seneca cannot execute the recommended trades without confirming your consent (either verbally or in writing) to the proposed changes. With respect to non- discretionary recommendations, Seneca cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that we would like to make a transaction for your account (including in the event of an individual holding or general market correction), and you are unavailable, we will be unable to effect the account transaction(s) (as we would for our discretionary clients) without first obtaining your consent. When you engage Seneca for Asset Management Services, we will ask you to provide us with information regarding your investment objectives, risk tolerance, financial situation, and other information, so that we can determine the recommended asset allocation that meets your goals and needs. Seneca, in coordination with the client, will use this information to establish investment guidelines for the management of the client’s assets. Any client-directed guidelines or changes to a client’s underlying financial situation or investment objectives must be submitted in writing to Seneca. Clients may also engage Seneca to manage certain investment products that are not maintained with the Firm’s primary custodian, such as variable and fixed annuity contracts, assets held in employer sponsored retirement plans and qualified tuition plans (e.g., 529 plans). In these situations, the “held-away” assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. When managing your assets, Seneca can be engaged to advise on the appropriate asset selection and/or allocation for held-away assets. We will then direct the provider or recommend to you any appropriate allocation among the various investment options that are available within the product. Financial Planning Seneca provides financial planning services to its clientele. Financial planning is an evaluation of a client’s current and future financial situation by using currently known variables to predict future cash flows, asset values and withdrawal plans. Financial planning services are offered to all clients, but a client is not required to utilize the service and may decline these services. Clients engaging us to prepare a financial plan only will be required to execute a Financial Planning Agreement that outlines the responsibilities of both the client and Seneca. The financial plan created by Seneca is based on our judgment and experience in evaluating the information provided to us by the Client. Client will retain the responsibility to arrange for implementation of the financial plan if Client desires. The services covered in the Financial Planning Agreement do not include specific investment recommendations, investment implementation, investment management, or ongoing monitoring of or updates to the plan or Client accounts. When engaged to prepare a financial plan, in most cases, the client will supply to Seneca information including income, investments, savings, insurance, age and many other items that are helpful to the Firm in assessing your financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, we will discuss your financial needs and goals with you and compare your current financial situation with the goals you state, your time horizon, and your comfort level surrounding volatility. Once these are compared, we will create a financial and/or investment plan to help you meet your goals. Once a financial plan is completed, a client may choose to engage Seneca to manage their assets or they may choose to engage another provider. We cannot stress enough the importance that you accurately and completely communicate to us the information we need. Our goal is to provide clients with the most personalized and complete financial plan as possible, as Seneca intends for clients to use it as a blueprint of how to meet their goals. To ensure that your plan remains accurate and up to date, it is very important that you continually update us with any changes to your financial situation, goals, or time horizon. All clients are offered the opportunity to engage Seneca for financial planning services. When a client engages Seneca to perform asset management and financial planning services, these services will require separate agreements. Retirement Plan Consulting Services Seneca serves as an “Investment Adviser” and a “fiduciary” within the meaning of Section 3(21) of Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, with respect to accounts in qualified retirement plans. Although 3(21) fiduciaries provide advice, they do not take control of plan assets, so the Plan Sponsor retains the final say regarding implementation of the recommended investment options. The fiduciaries of self-directed retirement plans (which can include 401(k) plans) are required to, among other things, determine a selection of investments from which the plan’s participants choose for their personal allocation in their individual participant account. Seneca provides plan sponsors assistance in meeting this obligation through a consultative relationship, which includes the recommendation of the plan investment options in accordance with the plan’s objectives, as well as the ongoing monitoring of those options to assist the plan sponsor in determining when changes to these options are needed. This advice is rendered on a non-discretionary basis, meaning the plan sponsor is free to accept or reject Seneca’s recommendations. Additional services which Seneca can provide, if requested by the plan sponsor, include participant registration, participant education, fee benchmarking, as well as assisting with the annual review and due diligence of the plan’s service providers. The Retirement Plan Consulting Services Agreement will specifically layout the services to be provided by Seneca to the plan sponsor and the plan. Assets Under Management As of February 28, 2024, Seneca has $379,362,468 in discretionary assets

under management and $1,064,425 in non-discretionary assets under management. Miscellaneous Disclosures Wrap Fee Programs. Seneca does not sponsor or participate in any wrap fee programs. Retirement Rollovers. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Seneca recommends that a client roll over their retirement plan assets into an account to be managed by Seneca, such a recommendation creates a conflict of interest if Seneca will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Seneca. ERISA / IRC Fiduciary Acknowledgment. When Seneca provides investment advice to a client regarding the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way Seneca makes money creates some conflicts with client interests, so Seneca operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule's provisions, Seneca must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Seneca gives advice that is in the client’s best interest;
• Charge no more than is reasonable for Seneca’s services; and
• Give the client basic information about conflicts of interest. Investment Risk. 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 by Seneca) will be profitable or equal any specific performance level(s). Client Obligations. In performing its services, Seneca will not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Seneca if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Seneca’s previous recommendations or services. Periods of Portfolio Inactivity. Seneca has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Seneca will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when Seneca determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, there can be no assurance that investment decisions made by Seneca will be profitable or equal any specific performance level(s). Cash Positions. Seneca considers cash and cash equivalents to be a material component of a client’s asset allocation. Depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Seneca may maintain cash and cash equivalent positions (such as money market funds, etc.) for defensive, liquidity, or other purposes. Unless otherwise agreed in writing, and with the exception of assets placed into the Flourish Cash Program, described below, all such cash and cash equivalent positions are included as part of assets under management for the purposes of calculating Seneca’s advisory fee. Clients are advised that cash and cash equivalent positions may miss market advances and there may be periods of time where the fee charged by Seneca exceeds the yield on cash and cash equivalent positions. Flourish Cash Program. Seneca may arrange for client access to a “Flourish Cash” account, which is a brokerage account offered by Flourish Financial LLC. Seneca is not affiliated with Flourish Financial LLC, and Flourish Financial LLC is not a bank. Seneca may offer this service under its own branding, and may help facilitate the transfer of client assets into and out of the Flourish Cash program, but at all times Flourish Financial LLC maintains responsibility for the execution and administration of the Flourish Cash program. The cash balance in a Flourish Cash account is swept from the Flourish Financial LLC brokerage account to deposit accounts at one or more third- party banks that have agreed to accept deposits from end-customers of Flourish Financial LLC (“Program Banks”). The accounts at Program Banks pay variable interest rates. The cash balance in a Flourish Cash account that is swept to one or more Program Banks is eligible for FDIC insurance, subject to FDIC rules, including FDIC aggregate insurance coverage limits. However, FDIC insurance will not be provided until the funds arrive at the Program Bank. There are currently at least 5 Program Banks available to accept deposits for institutional Flourish Cash accounts (accounts for corporations, partnerships and other legal entities) and at least 5 Program Banks available to accept deposits for personal Flourish Cash accounts (individual, joint and revocable trust accounts), and Flourish Cash is not obligated to allocate client funds across more than this number of Program Banks, even if there is a greater number of banks in the program. Clients are generally eligible for FDIC insurance coverage of $250,000 per client, per Program Bank, for each account ownership category. Therefore, clients are eligible for (i) up to $1,250,000 of FDIC insurance for either (A) an individual account or (B) an account for a revocable living trust in which one person is the only grantor, trustee and beneficiary of the trust (“Individual Revocable Trust Account”) and (ii) up to $2,500,000 of FDIC insurance for either (A) a joint account with two owners or (B) an account for a revocable living trust in which the same two persons are each the only grantors, trustees and beneficiaries of the trust (“Joint Revocable Trust Account”). The total FDIC coverage for a two-person household is calculated assuming that each household member has an individual account and that both household members share a joint account. If the number of Program Banks decreases for a client (either because a Program Bank is no longer participating in Flourish Cash, because a client's cash is not eligible to be swept to a Program Bank based on criteria set by the Program Bank (which will be disclosed at account opening), or because a client opts out of having their cash swept to a particular Program Bank), the amount of FDIC insurance for which the client would be eligible through Flourish Cash would be lower. Typically, all of a client's deposits at a Program Bank in the same ownership category (including deposits held outside Flourish Cash or held through multiple Flourish Cash accounts with the same ownership category) count toward the FDIC insurance limit for deposits at that Program Bank. Clients are responsible for monitoring whether they maintain deposits at a Program Bank outside of Flourish Cash and should consider opting out of having their cash swept to any such Program Bank to avoid exceeding FDIC insurance limits. Although Flourish Cash is offered through a brokerage account and cash held in brokerage accounts often has the benefit of SIPC protection, clients likely will not have the benefit of SIPC protection for cash held in their Flourish Cash account. Further, SIPC protection is not available for any cash held at the Program Banks. For additional information regarding FDIC coverage, visit https://fdic.gov/. Information about the Program Banks is available here. Seneca generally recommends the use of the Flourish Cash program with respect to client cash holdings that are not intended to be part of the client’s investment portfolio. Cash and cash equivalent positions that are included in a client’s investment portfolio allocation will generally not participate in the Flourish Cash program. Seneca does not assess an asset- based fee for assets maintained in the Flourish Cash program. Accordingly, Seneca is incentivized to recommend that clients minimize the amount of assets placed into the Flourish Cash program and/or to allocate Flourish Cash program assets to investment positions which would be subject to Seneca’s asset-based fees.