A. Orchard Capital Management, LLC Orchard Capital Management, LLC (“Orchard Capital”, “Orchard” and/or “the firm”) is an Illinois limited liability company. The firm is owned by Blake Harper, Joshua Fairbank, and Michael Valencia. B. Advisory Services Offered Orchard Separate Account Management Services Orchard Capital seeks to manage its client portfolios primarily on a discretionary basis, for which Orchard Capital receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this brochure. The firm also has discretionary authority to select and retain outside investment managers. Unless a client notifies Orchard Capital in writing of specific objectives or restrictions, accounts will reflect a model portfolio that is predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. Orchard Capital’s investment advisory services to clients take into account a client's personal financial circumstances, investment objectives and tolerance for risk. Orchard Capital’s engagement with a client will include, as appropriate, the following: ▪ Providing assistance in reviewing the client's current investment portfolio against the client's personal and financial circumstances as disclosed to Orchard Capital in response to a questionnaire and/or in discussions with the client and reviewed in meetings with Orchard Capital. ▪ Analyzing the client's financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying an appropriate portfolio. ▪ Reporting to the client on a quarterly basis as agreed upon with the client, information on contributions and withdrawals in the client's investment portfolio, and the performance of the client's portfolio measured against appropriate benchmarks (including benchmarks selected by the client). ▪ Proposing changes in the client's investment portfolio in consideration of changes in the client's personal circumstances, investment objectives and tolerance for risk. In addition to providing Orchard Capital with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are obligated to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals, and tolerance for risk. Orchard Capital will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Orchard Capital will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives, and tolerance for risk. Integrated Planning and Personal Financial Advisory Services For certain clients (primarily family office and related entities), Orchard Capital agrees to assess the client’s current financial condition, review the client’s investment goals and objectives and prepare an integrated financial plan that may include ▪ An Investment Policy Statement and asset allocation recommendations for consideration by the client ▪ Goal planning and goal assessment in the context of long-term financial and related plans ▪ Financial and performance reporting and updates on assets data provided by the client Orchard Capital will prepare periodic updates with respect to investment allocation, financial planning and financial reporting on a quarterly, semi-annual or annual basis (as selected by the client) and at the specific request of the client. The client is under no obligation to implement any recommendations of Orchard Capital, and the client understands that it will be responsible for all decisions with respect to implementation. The client may from time to time authorize Orchard Capital to execute non-discretionary transactions on behalf of the client. Telephone calls to Orchard Capital may be recorded for data verification, and the client consents to such recording. Family Office and Specialized Services If requested by the client, Orchard Capital will perform other services on a fee-for-service basis. These may include the following: ▪ Specialized Investment Services – Investment due diligence, illiquid investment tracking and third-party services sourcing. ▪ Estate Planning and/or Coordination Services – Review of existing estate planning strategies, assessment of current estate plan with established goals, integration of asset placement and allocation with long-term plans and coordination and/or sourcing of specialized providers of estate-related services (i.e., legal counsel, tax counsel, specialized structures, etc.). ▪ Incremental planning, expense management, concierge, financial or other services. ▪ Recommending

separate account managers, each matched to the asset categories in the client's targeted asset allocation for consideration by the client. ▪ Other ancillary services as needed and agreed by the client and Orchard Capital, including but not limited to philanthropy coordination and/or research, wealth transition, business succession and business planning services. Institutional Asset Management Orchard Capital operates private funds and serves as the sub-advisor to a UCITS fund available to non-US investors. Advisory clients of Orchard Capital may hold interests in these securities, which may represent a conflict of interest in that the firm will be receiving management fees for the fund. Important information for the registered UCITS fund is detailed in its prospectus and statement of additional information, and the important information for the private funds are detailed in each fund’s private placement memorandum, subscription documents, and other documentation. Investment Advisory and Asset Management Services to Sanctuary Wealth Group Asset Allocation Advisory Orchard may provide Sanctuary Wealth Group and its registered investment affiliates advice on (i) asset allocation strategy, (ii) recommending various separate account managers, including Orchard, (iii) recommending model portfolio providers, (iv) providing access to various third-party research providers, and (v) administering the Sanctuary Alternative Solutions Platform as further described below. Sanctuary Alternative Solutions (“SAS”) Platform In addition to the asset allocation advisory services described above, Orchard and or its affiliates administer a platform exclusively available to Sanctuary Wealth Group and its affiliate entities’ clients. Such clients may access asset allocation strategies and affiliated and unaffiliated asset management services through the SAS Platform. Once Orchard and its affiliate entities formulate the asset allocation strategy recommendations and Sanctuary Wealth Group approves such strategies, Orchard and its affiliate entities identify specific private funds to complement the asset allocation strategy. Once the funds have been identified, they must successfully pass a rigorous due diligence process and be approved by Sanctuary Wealth Group. Upon approval, such private funds are included in the SAS Platform. SAS Platform Fund Management – Orchard as a Platform Fund Manager Orchard and its affiliate may provide discretionary investment advisory services to a limited group of private investment funds (each a “fund”, and, collectively, the “funds”), including those in a fund of funds structure in which Orchard, its principals, or affiliates serve as the investment manager. Orchard allocates the funds’ capital in two primary ways: to private investment vehicles (“underlying investment funds”) managed by third-party investment managers (“underlying fund managers”), and within Orchard or an affiliated fund team within Orchard or an affiliate (“affiliated fund managers”). In some cases, a fund may include both underlying investment funds and Orchard strategies, either in a separate account within the fund or as an Orchard fund allocation or both. Interests in private funds are offered on a private placement basis via exemptions that are in compliance with the exemptions provided by either Section 3(c)1 or Section 3(c)7 of the Investment Company Act of 1940, as amended (the “Company Act”) to persons who are either “accredited investors” as defined under the Securities Act of 1933, as amended (the “Securities Act”), or “qualified investors” as defined under the Investment Advisers Act of 1940, or “qualified purchasers” as defined under the Investment Company Act of 1940, and subject to other conditions set forth in each fund’s respective offering documents. See Item 6 of this brochure for performance-based fee disclosures. Platform, Research, Technology, and Administration Fees Orchard and affiliates may provide services including research, platform, technology, and administration services to funds and Sanctuary Wealth Group affiliate entities. Such services may include billing, performance reporting, and platform administrative services. C. Client-Tailored Services and Client-Imposed Restrictions Other than those accounts that invest in one or more Orchard Capital model portfolios, the client’s account will be managed on the basis of the client’s financial situation and investment objectives. Reasonable restrictions may be imposed by the client on the management of any account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Orchard Capital does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) E. Client Assets Under Management As of December 31, 2022, Orchard Capital had SEC regulatory assets under management of $355.7 million on a discretionary basis, and $600,000 on a non-discretionary basis.