Frost Investment Services, LLC (“we,” “us,” “our,” or “FIS”) is a retail investment adviser registered with the SEC, established in November 2016 and first registered in January 2017. FIS is a wholly owned subsidiary of Frost Bank (“Frost Bank”). Frost Bank is a wholly owned subsidiary of Cullen/Frost Bankers, Inc. As of December 31, 2023, FIS had total discretionary assets under management of $2,664,750,805. There are no non- discretionary assets under management. We offer investment advisory services to clients (“you,” “your,” or “yours”) through personal consultations designed to obtain detailed financial information and other pertinent data. In formulating the investment advice to you, factors that we may consider include the following:
• Financial and personal circumstances
• Risk tolerance
• Investment horizon
• Liquidity needs
• Tax considerations
• Financial goals
• Income (current and potential)
• Portfolio size
• Net worth
• Investment objectives
• Any other issues important to your state of affairs You should notify us promptly if there are any changes in your financial situation or investment objectives. You should also notify us if you wish to impose any reasonable restrictions upon the management of your account. Portfolio Management We offer a variety of investment strategies, typically managed to an allocation model designed to diversify your securities portfolios. We offer equity and fixed-income management, providing a range of style-based investment approaches, including:
• Capital appreciation
• Growth
• Growth and income
• Taxable and tax-exempt fixed-income objectives Assets are allocated within a mix of securities that include all or some of the following:
• Stocks
• Bonds
• Mutual funds
• Exchange-traded products (“ETPs”), including exchange-traded funds (“ETFs”) FIS has entered into an agreement with our affiliated registered investment adviser, Frost Investment Advisors, LLC (“FIA”), to provide asset allocation models. The asset allocation models are primarily focused on diversification and minimizing volatility in a portfolio by distributing assets across a broad spectrum of asset classes. FIA provides guidance to FIS as to the securities to be bought, sold, or held in each asset allocation model, as well as the percentage of the model portfolio to be invested in each underlying security. Within the allocation model guidelines, your FIS investment adviser representative maintains discretion over the implementation of any advice received from FIA. Although diversification may reduce volatility, it does not ensure a profit or guarantee against a loss. In January 2023, FIS migrated advisory accounts transitioned from the Envestnet Asset Management, Inc. (“Envestnet”) managed platform to the Fidelity Managed Account Xchange (“FMAX”) platform. FMAX is an integrated managed account program sponsored by Fidelity Institutional Wealth Adviser, LLC (“FIWA”), an unaffiliated registered investment adviser. FIWA is a wholly owned subsidiary of FMR LLC and, together with its affiliates and subsidiaries, is generally known to the public as “Fidelity Investments” or “Fidelity.” Implementation Manager FIWA has retained Envestnet to provide model implementation, overlay management, and other administrative duties. Envestnet will have discretionary authority over client accounts and will be responsible for the implementation of models received from model providers within the FMAX platform. FMAX is designed to provide a highly configurable investment advisory platform, which FIS will use to provide wealth management solutions directly to our clients. FMAX will also provide risk-based portfolio management tools, including portfolio modeling and diagnostic tools, rebalancing, drift tolerance controls, and system-generated alerts related to drift and rebalancing; and administrative services, including risk tolerance questionnaires, investment due diligence, performance reporting, and fee-billing. Through the FMAX platform, FIS has four distinct offerings for advisory clients to consider: 1) the Fund Strategist Portfolio Program, 2) Optimum Asset Allocation Strategy, 3) Advisor Model Management, and 4) the Unified Managed Accounts Program. Fund Strategist Portfolio Program The Fund Strategist Portfolio Program (“FSP Program”) provides a menu of prepackaged investment models provided by unaffiliated, third-party investment managers (“Investment Managers”). In the FSP Program, the asset allocation and underlying investments are provided by the Investment Managers on a model basis. These Investment Managers construct an allocation for their model and select the underlying investments, including actively managed, passively managed, and registered alternative mutual funds and exchange-traded

products, including mutual funds and ETFs, which, when discussed together, are hereinafter referred to as (“Funds”). A model’s risk rating allows FIS to select models aligned with a client’s risk profile and investment objectives. Optimum Asset Allocation Strategy The Optimum Asset Allocation Strategy is also an FSP Program that provides a menu of prepackaged investment models provided by FIS affiliate Frost Investment Advisors, LLC (“FIA”) as the Investment Manager. In the Optimum Asset Allocation Strategy, the asset allocation and underlying investments are provided by FIA on a model basis. FIA constructs an allocation for its models and selects the underlying investments, including proprietary Frost Funds and non-proprietary Funds. Advisor Model Management The Advisor Model Management (“AMM”) is also known as Advisor Portfolio Manager (“APM”). AMM offers a customized investment program using asset allocation models and proprietary portfolios offered through FIA. In the AMM offering, the asset allocation and underlying investments are provided by FIA. As the Investment Manager, FIA constructs an allocation for their models and selects the underlying investments using proprietary Frost Funds, including equities and individual bonds. FIA provides investment due diligence and performance reporting. For additional information, please refer to the Frost Investment Advisors, LLC, Form ADV Brochure available on the SEC’s website at www.adviserinfo.sec.gov. Unified Managed Account Program The Unified Managed Account (“UMA”) Program enables clients the ability to incorporate multiple Funds and strategies into a single account by accounting for each unique investment strategy as a unique investment “sleeve” within a single account (e.g., Fund sleeves, individual Separately Managed Account (“SMA”) manager sleeves, and Fund Strategist sleeves). FIS may develop a UMA portfolio for a client by first creating their own asset allocation. FIS then determines the investment solution(s) to utilize within the UMA from the options available on the platform, including investment models, SMAs, Funds, and individual securities. Tax and Impact Overlay Services For UMA accounts that meet certain sleeve minimum requirements, FIS offers clients the ability to utilize tax and/or impact overlay services (“Tax Overlay” and “Impact Overlay”). Tax Overlay seeks to enhance after-tax returns by analyzing holdings and trading activities in an account. Impact Overlay allows the integration of Environmental, Social, and Governance (“ESG”) factors into the management of a client’s account. If selected, the Implementation Manager provides the Tax Overlay and/or Impact Overlay services to an account or sleeve. Neither FIS, FIWA, nor Envestnet provide tax planning advice or services, and therefore, clients should consult their accountant or tax professional. The Impact Overlay is administered by FIWA who determines the factors that qualify an investment for that designation. The FIWA research team follows a proprietary ESG evaluation framework to qualitatively evaluate a given Fund’s or SMA’s ESG intent (if any), whether such intent has been consistent and is aligned with its investments and ESG outcome, and the level of commitment and engagement that exist to support the intended ESG outcome and reporting. FIS does not conduct an independent assessment of an investment’s ESG factors. For additional information, please refer to the Fidelity Institutional Wealth Adviser LLC, Form ADV brochure titled “Fidelity Managed Account Xchange,” available on the SEC’s website at www.adviserinfo.sec.gov. Financial Planning We can prepare and provide you with a written financial plan designed to help you achieve your financial goals and investment objectives. The preparation of such a plan necessitates that you provide us with personal data such as:
• Family records
• Budgeting
• Personal liabilities
• Estate information
• Additional financial goals The financial plan may include any of the following as requested or directed by you and agreed upon by contract:
• Asset protection
• Tax planning
• Business succession
• Strategies for exercising stock options
• Cash flow
• Education planning
• Estate planning and wealth transfer
• Charitable gifting
• Long-term care and disability planning
• Retirement planning
• Insurance planning
• Risk management We do not provide accounting, tax, or legal advice. Should you choose to implement the recommendations contained in the plan, we suggest working closely with your attorney and accountant. Financial planning is included in our advisory fee. Please refer to our management fee schedule below.