3 accommodate the needs or objectives of specific clients but rather to enable the Primary Adviser to match their clients with SMAs that are consistent with their investment goals and objectives. RVC generally receives Sub-advisory Client information through the Primary Adviser and relies on the Primary Adviser to forward current and accurate sub-advisory client information on a timely basis to assist in RVC’s day-to-day management of sub-advisory clients’ accounts. Sub-advisory clients may also contact RVC directly concerning their accounts. During the dual contract period, the Primary Adviser will remain responsible for determining sub-advisory clients’ investment objectives and whether one or more of RVC’s SMAs are suitable to meet such investment objectives. This includes performing initial and ongoing client suitability reviews for the sub-advisory client’s account(s). The Primary Adviser is responsible for obtaining and evaluating information regarding the identity, circumstances, financial condition, tax situation, regulatory status, and financial needs and goals of the sub-advisory client so that the Primary Adviser can evaluate whether the investment guidelines of the sub-advisory client are appropriate and suitable. The Primary Adviser reviews the investment guidelines outlined in the dual contract investment management agreement between RVC and each shared Sub-advisory Client, as they may be amended from time to time, and informs RVC, and each shared Sub-advisory Client, if any such investment guidelines are not appropriate or suitable for any such shared sub-advisory client. RVC periodically communicates investment performance and portfolio commentary to the Primary Adviser, which employs its own discretion in forwarding such information to Sub-advisory Clients. The Primary Advisor is responsible for determining their methods for maintaining books and records and delivering them to the Sub-advisory Clients, including preparing and sending performance reports and marketing materials. RVC is responsible for delivering Parts 2A, 2B and Part 3, the Client Relationship Statement (“Form CRS”) and its Privacy Policy to the Primary Adviser. The Primary Adviser is responsible for delivering such documents to Sub- advisory Clients. When RVC serves as discretionary sub-advisory account manager, it will include the account assets in RVC’s Regulatory Assets Under Management (RAUM). Outsourced Chief Investment Officer (“OCIO”) Services RVC offers sub-advisory Outsourced Chief Investment Officer (OCIO) services to third-party SEC and state-registered investment advisers, financial planning firms, broker-dealers, and other financial institutions (the “Primary Adviser”) that maintain ongoing relationships with clients. In these instances, RVC is a consultant to the Primary Adviser who selects RVC for OCIO services. RVC, as a consultant, provides investment recommendations, model portfolios, ongoing monitoring of investment strategies, fund and portfolio construction analytics, portfolio optimization, bespoke investment management solutions, outsourced trading, technology, research, and financial support in exchange for a fixed-dollar amount fee or as a percentage of assets under management. RVC has discretion over client investment portfolios and has access to personal information about clients but does not vote proxies. In these instances, a Primary Adviser selects RVC to provide these services, and for this service, the Primary Advisor is charged a separate fee for OCIO services. The consulting services are disclosed in the Primary Advisor’s brochure. The compensation for RVC depends on the negotiated agreement between the Primary Advisor and RVC. RVC’s fee varies based on the scope and complexity of supporting the advisor's services. In these instances, RVC physically manages OCIO clients’ portfolios via trading and operational services. Either the Primary Adviser provides trading access to RVC through its technology, or RVC provides the technology. The managed accounts are discretionary and considered Regulatory Assets Under Management (RAUM). Model Portfolio Services RVC is a Turnkey Asset Management Platform (“TAMP”) strategist and provides non-discretionary investment advice through a model portfolio delivery service. Under such arrangements, RVC provides investment strategies to registered investment advisers, broker-dealers, and TAMP providers. RVC provides these clients with allocations to its investment models and continuous updates on all model changes. RVC provides continuous and ongoing portfolio research services to these clients on a direct and reverse inquiry basis. The model portfolios and the recommendations implicit in the model portfolios generally are not tailored to third- party clients' specific needs or circumstances. RVC does not have an advisory relationship with the end-investor under model licensing arrangements. The third party retains the discretion to implement, reject, or adjust such a model, and the third party is responsible for executing any corresponding transactions on behalf of the third party’s underlying clients. RVC does not affect or execute transactions for any underlying clients of the third party participating in the model portfolio delivery service. RVC does not consider such underlying clients of the third party to be clients of RVC. In instances where RVC has no discretion to effect trades and no supervisory responsibility over the assets in the program, RVC does not include the assets under management for these accounts in total Regulatory Assets Under Management (RAUM) but categorizes them as Assets Under Advisement (AUA). Separately Managed Account (“SMAs”) RVC renders advice and services to institutional and non-institutional investors (the “clients”) through separately managed accounts (“SMAs”). Clients must first execute an investment management agreement that provides RVC with discretionary authority to invest all or some of the client’s assets in one or more of RVC’s SMAs. Once discretionary authority from the client is granted, RVC will select securities and execute transactions without the client's permission before each transaction. RVC’s advice and services for its clients are subject to each client’s investment objectives and guidelines, as outlined in their respective Investment Management Agreement or applicable governing documents.
Consulting RVC offers consulting services to institutional investors and broker-dealers, including customized analysis and reports on the economy and financial markets, various asset classes, sectors, and investment strategies. These services are provided pursuant to specialized engagements individually negotiated with RVC’s clients based upon their specific needs and objectives. In addition to the fixed fee RVC shall receive pursuant to the terms set forth in a consulting agreement, RVC may receive bonus compensation at the discretion of the client. In performing these services, RVC is not required to verify any information received from the client or from the client’s other professionals (i.e., attorney, accountant, etc.) and is authorized to rely on such information. RVC may recommend its services, and/or the services of other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if RVC recommends its own services or the services of any of its affiliates (as set forth in Item 10 below). The client is under no obligation to act upon any of the recommendations made by RVC under a consulting engagement or to engage the services of any such recommended professional, including RVC itself. The client retains discretion over all such implementation decisions and is free to accept or reject any of RVC’s recommendations. Clients are advised that it remains their responsibility to promptly notify RVC if there is a change in their financial situation or investment objectives. Research RVC publishes market research and investment commentary for certain parties, including shareholders of the RICs we manage, investment advisory clients, and prospects. The research publications provide these parties with the basis for the investment strategies we employ in managing registered investment companies or portfolios in which these parties may have invested client funds. Sight Beyond Sight® (the “Newsletter”) is a bona fide publication of general and regular circulation offering and is limited to the dissemination of impersonal and objective investment-related information, together with access to additional impersonal investment-related information and links, and does not provide individualized advice or recommendations for any specific reader. Neil Azous is the Editor-in-Chief, and Michael Sedacca is a contributor. RVC provides complimentary subscriptions of Sight Beyond Sight® to investment advisory clients or prospective clients who meet the eligibility requirements as accredited investors as defined under the Securities Act of 1933. RVC may deliver Sight Beyond Sight® to non-investment advisory clients for an agreed-upon payment via a subscription service. RVC may market and implement investment strategies and expressions referenced in the newsletter with investment advisory clients or prospective clients. The commentary, analysis, opinions, advice, and recommendations in the newsletter represent the personal and subjective views of the Editor/Contributors and are subject to change at any time without notice. The information in the newsletter is obtained from sources that the Editor/Contributors believe to be reliable. However, the Editor/Contributors have not independently verified or otherwise investigated all such information. Neither the Publisher, the Editor, nor any of their respective affiliates guarantees the accuracy or completeness of any such information. The newsletter is not a solicitation or offer to buy or sell any securities. Further, the newsletter is not intended to be a solicitation for investment advisory services offered by RVC. Additionally, readers are not required to utilize the services of any Investment Adviser Representative of RVC in such an individual’s capacity. When at all possible, the Editor/Contributors of the newsletter will avoid making recommendations on securities owned by investment advisory clients of RVC. If conflicts arise, those holdings will be disclosed. Administrative Services RVC offers certain administrative services to a limited number of clients. Such administrative services typically include oversight of certain recordkeeping and reporting functions, budget and expense review, and similar administrative functions (collectively, “Administrative Services”). RVC is entitled to receive compensation in connection with the provision of such services, either as a percentage of assets under administration or a fixed fee. Personal Services RVC may support our clients beyond traditional portfolio management and financial planning. RVC may coordinate between our clients and their attorneys, tax advisors, insurance advisors, and private bankers. RVC may track clients’ entire financial picture, including various trusts, personal and business entities, and investments not held by our custodians. Retirement Plan Services RVC may provide advisory services to qualified and non-qualified retirement

plans, including 401(k) plans, 403(b) plans, pension plans, profit-sharing plans, defined benefit plans, and deferred compensation plans. Services include both non-fiduciary and fiduciary services to the sponsor of the Plan (the “Plan Sponsor”) and the participants of the Plan (the “Plan Participants”), which RVC performs in accordance with the Employee Retirement Income Security Act (“ERISA”) rules. For example, RVC may act as either: ▪ Non-Fiduciary: RVC would act as a limited scope ERISA 3(21) non-fiduciary that can advise, help, and assist plan sponsors with their investment decisions. The plan sponsor is still ultimately responsible for the decisions made in their plan, and RVC may assist in mitigating that plan sponsor’s liability by following a diligent process. However, the plan sponsor remains liable. ▪ Fiduciary: RVC may act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. RVC would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. Advisory services are negotiated based on the needs of the Plan and the direction and engagement by the Plan Sponsor and are included in the terms of the RVC applicable consulting or investing management agreement. Currently, RVC does not engage in such retirement-related services but may do so in the future. Services Limited to Specific Types of Investments Advice regarding specific types of investments include, but are not limited to, the following: ▪ Equities ▪ Open-End Mutual Funds (OEF) ▪ Closed-End Funds (CEF) ▪ Exchange-Traded Funds (ETF) ▪ Government fixed income securities ▪ Treasury inflation protected/inflation-linked bonds ▪ Corporate debt securities ▪ Foreign Exchange ▪ Commodity Interests ▪ Futures/Options ▪ Precious Metals ▪ Volatility ▪ Options contracts on securities ▪ Listed and over-the-counter (OTC) derivatives ▪ Hedging solutions RVC may use other securities as well, including derivatives, to speculate, leverage, diversify or hedge a portfolio when applicable. RVC seeks to ensure that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of RVC’s economic, investment, or other financial interests. To meet its fiduciary obligations, RVC attempts to avoid, among other things, conflicts around investment or trading practices that systematically advantage or disadvantage certain client portfolios. Accordingly, RVC’s policy is to seek fair and equitable allocation over time with respect to the allocation of investment opportunities among its clients. RVC ensures its trade allocation policies and procedures are followed by all employees and that employees are trained periodically to ensure they understand the conflicts inherent in this space and the controls designed to mitigate such conflicts to ensure they avoid favoring one client over another—particularly those with differing fee structures managed alongside one another (i.e., “side by side management”). C. Client Tailored Services and Client Imposed Restrictions RVC offers the same suite of services to all its eligible clients. However, specific client investment strategies and their implementation are dependent upon suitability—such that the client’s current situation (financial goals, income, tax levels, time horizon, liquidity needs, and risk tolerance levels) is considered. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. RVC then manages that client’s assets using a combination of one or more of the following investment solutions: ▪ Internally managed registered investment companies developed by RVC. ▪ Internally managed model portfolios developed by RVC. RVC manages assets primarily on a discretionary basis. RVC has investment control to implement the investment plan RVC has developed with a client without obtaining the client’s consent before making a trade or allocation. RVC, in other circumstances, may act on a non-discretionary basis to manage client assets, such as by recommending investment opportunities to clients; however, such clients have the final authority to implement these recommendations. For Regulated Investment Companies (referred to herein as “fund” or “fund’s”), this generally involves investing a fund’s assets in accordance with its organizational and offering documents. RVC manages a fund on a fully discretionary basis. Investors in a fund cannot restrict how RVC manages the fund or the assets held by the fund because the fund’s Prospectus and Statement of Additional Information govern all the fund’s investments. For SMAs, this generally involves allocating the client’s assets among the above-described investment solutions. Clients may impose reasonable restrictions on how RVC manages assets in their accounts. The determination as to what a “reasonable restriction” is is solely RVC’s. To the extent that a client imposes a restriction that would impact RVC’s ability to implement the strategy for that account, RVC reserves the right to reject, refuse to manage, or liquidate the account. RVC may recommend investments in RVC’s affiliated ETFs for client accounts, including accounts for owners, officers, and investment advisor representatives associated with RVC. If you have engaged RVC for discretionary management services, RVC may invest a percentage of your assets in the Fund, up to 100%, without your further approval. Securities held in SMAs, including accounts for owners, officers, and other individuals associated with RVC, may also be the same securities as those purchased by the Rareview Fund(s). Material Conflict of Interest. In discretionary advisory arrangements, RVC is authorized, without prior consultation with the client, to buy RVC’s affiliated ETFs, in which event, RVC shall receive both a management fee payable by the affiliated ETF and an advisory fee. Because we receive compensation from the ETF, there is a material conflict of interest, as we have a financial incentive to invest your assets in the ETF or to recommend that you invest in the ETF rather than other investments. When you use RVC’s advisory services, RVC can receive two payments from your investment. One payment is for services RVC provides to you, as outlined in the Investment Management Agreement. The second fee is from the payments RVC receives from the ETF itself. However, RVC will only make such investments and/or recommendations where RVC believes it is consistent with RVC’s fiduciary duty and your investment objectives. RVC will make a reasonable faith effort to determine if an investment in a Rareview ETF is in your best interest after considering such factors as your goals, time horizon, risk tolerance (items contained in the Client Information Form provided to SMA Clients during onboarding); and the strategies, fees, and expenses of other comparable ETFs. Aside from the Client Information Form, RVC provides no formal documentation of this analysis. You can purchase ETFs directly without RVC’s advisory services. By doing so, you would be declining RVC’s advisory services, which are designed to assist you in determining investments most suitable to your needs, objectives, and risk tolerance. By using RVC’s advisory services and agreeing to the fee associated with these services, you are consenting to the conflict of interest referenced above. Any questions pertaining to this conflict of interest and the way RVC mitigates its conflicts, and any other issues should be addressed with our Chief Compliance Officer, who may be contacted at 212- 475-8664. RVC does not provide general financial planning, tax, legal and/or insurance advice, unless specifically stated in a signed agreement specifying such services and the fees for these additional services. However, RVC may recommend potentially suitable parties to furnish these services to investors upon request. D. Wrap Fee Programs RVC does not sponsor or participate in a wrap fee program. E. Assets Under Management As of May 13, 2024, RVC managed $288,308,118 on a discretionary basis and $0 on a non-discretionary basis. Total Regulatory Assets Under Management (RAUM) was $288,308,118. As of May 13, 2024, RVC oversees $47,888,767 in advisory assets which are non-managed strategies powered by RVC’s OCIO Services, Model Portfolio Services, or other non-managed investment assignments. Total Assets Under Advisement (AUA) was $47,888,767. As of May 13, 2024, on a combined basis, RAUM and AUA was $336,196,884. F. Internet Presence RVC operates and supervises the following website and social network listings: Website LinkedIn Twitter YouTube www.rareviewcapital.com Rareview Capital LLC @rareviewcapital @rareviewcapital G. Physical Office Locations Principal Office and Mailing Address: 1980 Festival Plaza Drive, Suite 300, Las Vegas, NV 89135 Places of Business: Norwalk, CT, Woodbury, CT, Hartford, CT The fees applicable to each client are set forth in detail in their respective Investment Management Agreement. For those invested in pooled vehicles, the fees are set forth in each fund’s Prospectus and Statement of Additional Information. A summary of such fees is provided below. Generally, clients pay RVC a fee for investment management services (the “Management Fee”) and may also be charged a performance-based fee or profit allocation (“Performance Compensation”). In the event of a sub-advisory relationship in which RVC is the primary investment advisor, RVC will adhere to the advisory agreement or other legal document to render payment directly or indirectly to that organization while meeting the specific and agreed-upon terms in all cases. Certain clients may invest in registered investment companies – open-end mutual funds, closed-end funds, exchange traded funds – or other third-party investment products. In such cases, advisory compensation charged by the applicable third-party investment adviser will be paid by the client in addition to the advisory compensation outlined herein, which is paid to RVC. Full details regarding the services, fees, and other terms applicable to clients are included in their respective Investment Management Agreements and in the relevant pooled vehicles’ offering documentation (Prospectuses and Statements of Additional Information). Performance compensation is charged in compliance with all applicable requirements of Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). For the avoidance of doubt, RVC, in its sole discretion, may waive, reduce or rebate any Management Fee or Performance Compensation. In addition, Management Fees and/or Performance Compensation may also be calculated differently with respect to, or may not be charged to, certain separately managed accounts, including affiliate-owned separately managed accounts, if any. As noted above, full details regarding the services, fees, and other terms applicable to clients are included in their respective Investment Management Agreements.