A. First Ascent is an investment adviser that was organized as an LLC in the state of Delaware on August 27, 2015, licensed by the Colorado Division of Securities on January 27, 2016, then subsequently with the SEC on June 1, 2018. Currently all employees have ownership in the Firm along with independent outside investors, with Scott MacKillop-CEO, as the largest shareholder. The Firm has voluntarily subscribed to the “Real Fiduciary™ Practices” published by The Institute for the Fiduciary Standard. Real Fiduciary™ Practices offer a simple code of conduct and outline a commitment to clients of subscribing financial advisors. They seek to clearly articulate what a client can expect to receive from a subscribing financial advisor. These Real Fiduciary™ Practices do not replace our regulatory compliance obligations or duties to clients under relevant laws, rules, or regulations. The Institute for the Fiduciary Standard’s role is limited to publishing the practices as well as maintaining a corresponding register of subscribing financial advisors. You can verify our affirmation of Real Fiduciary™ Practices on our website or at the Institute for the Fiduciary Standard website at www.thefiduciaryinstitute.org. The practices can be found at https://thefiduciaryinstitute.org/wp- content/uploads/2019/03/Real-Fiduciary-Practices-2019-02-22.pdf B. First Ascent’s primary business is managing portfolios for the clients of independent financial advisors. In very limited circumstances, we will also manage portfolios for clients on a direct basis, which are mostly friends and family accounts. First Ascent manages portfolios on both a discretionary and a non-discretionary (platform model portfolio) basis. Portfolios managed on a discretionary basis, through independent financial advisors and/or broker-dealers provide model portfolios and the tailoring of portfolios for certain restrictions or requirements of an individual client. First Ascent enters into a direct investment management relationship with the client, and with the client’s financial advisor or it can also act as a sub-advisor to their financial advisor or broker/dealer. First Ascent also provides model portfolios to technology platform providers who offer them to advisors who use the platform. The platforms provide trading,

performance reporting, billing, proposal generation, onboarding, and client and advisor portals. Our model portfolios are offered on a non-discretionary basis through these platform firms. The firms that use our model portfolios are solely responsible for implementing all trading recommendations and providing administrative and performance reporting to their clients. Our portfolios consist of but are not limited to mutual funds and exchange traded funds (“ETFs”). We do not have or use any proprietary products in our portfolios. First Ascent also provides sub-advisory services to other registered investment advisors. Services include: (a) continuous monitoring of the model portfolios and underlying funds or separate account managers; and (b) investment recommendations in accordance with the investment objectives, policies and limitations stated within the Investment Policy Statement. In addition, First Ascent provides Fiduciary 3(38) Investment Management Services to employee benefit plans which are established and maintained by the sponsor of the plan (“Plan”) in accordance with applicable provisions of the Internal Revenue Code and the Employee Retirement Income Security Act of 1974 (“ERISA”). The Plan provides that the investment authority of its assets is vested in the sponsor, and that the sponsor is a “named fiduciary” thereunder as contemplated by Section 402(c)(3) of ERISA; and has the power to appoint investment managers as that term is defined in Section 3(38) of ERISA. The 3(38) investments provided include, but are not limited to, certain of First Ascent’s Model Portfolios, an investment line-up using securities representing a spectrum of asset classes and risk levels, and a qualified default investment alternative (or “QDIA") for the Plan, if required. First Ascent also produces educational material on investment-related topics through brief client or advisor focused presentations, videos and webinars available on the Navigator Investor Education page on its website. The Firm also hosts a series of webinars for advisors, conducted by guest industry leaders, called “Master Class Series”. There is no cost to either the client or advisor to access this information. C. Portfolios managed on a discretionary basis may, upon reasonable request, include other securities or types of investments, which may include a security proxy for a security held in a model portfolio. Clients may impose certain other reasonable restrictions on securities such as transferring in securities to be held long-term and not sold. We will also work with the client and their advisor on an orderly liquidation of transferred-in securities that have embedded capital gains. D. We do not participate in any wrap-fee programs. E. As of December 31, 2022, First Ascent had $1,367,980,200 of regulatory assets under management, $252,395,610 of which were non-discretionary.