A. Firm Information Harrell Investment Partners, LLC (“HIP” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Texas. HIP was founded in September 2018 and is owned by Robert K. Harrell II (Principal). The Chief Compliance Officer of HIP is Dilda Dalvi. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by HIP. B. Advisory Services Offered HIP offers investment advisory services to individuals, high net worth individuals, and charitable organizations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. HIP's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services HIP provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and continuous financial planning services. HIP utilizes a four-step approach to help ensure it fully understands and addresses client needs while providing flexibility to its clients with respect to their investment needs. ● Discover: HIP will first spend time with the client, asking questions, discussing the Client’s financial situation and investment experience, and broadly identifying major goals of the Client. ● Design: HIP will review and analyze the information provided by the Client. Based on its reviews, HIP generally develops with each Client: o a financial outline for the Client based on the Client’s financial situation and goals, and the client’s risk tolerance level (the “Financial Profile”); and o the Client’s investment objectives and guidelines (the “Investment Plan”). The Financial Profile is a reflection of the Client’s current financial picture and a look to the future goals of the Client. The Investment Plan outlines the types of investments HIP will make or recommend on behalf of the Client based on HIP’ own research and analysis in order to meet those goals. The elements of the Financial Profile and the Investment Plan are discussed periodically with each Client, but are not necessarily written documents. The Investment Plan will be updated from time to time when requested by the Client, or when determined to be necessary or advisable by HIP based on updates to the Client’s financial or other circumstances. ● Implement: To execute the Client’s Investment Plan, HIP will manage the Client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the Client. As a discretionary investment adviser, HIP will have the authority to supervise and direct the portfolio without prior consultation with the Client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the Client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Page 5 Manage: HIP will monitor the investment performance of Client accounts relative to their Financial Profiles on an ongoing basis. Notwithstanding the foregoing, Clients may impose certain written restrictions on HIP in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each Client should note, however, that restrictions imposed by a Client may adversely affect the composition and performance of the Client’s investment portfolio. Each Client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the Client’s account. For these and other reasons, performance of Client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and Clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar Clients of HIP. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor

will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will HIP accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services - HIP will typically provide a variety of continuous financial planning services. Such services may be included in the overall advisory services or contracted separately, based on the Client’s needs and complexity of the services to be provided. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. Depending on a Client’s particular situation, financial planning services may include some or all of the following: ● Gathering factual information concerning the Client’s personal and financial situation; ● Assisting the Client in establishing financial goals and objectives; ● Analyzing the Client’s present situation and anticipated future activities in light of the Client's financial goals and objectives; ● Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems; ● Making recommendations to help achieve retirement plan goals and objectives; ● Designing an investment portfolio to help meet the goals and objectives of the Client; ● Providing estate planning; ● Assessing risk and reviewing basic health, life and disability insurance needs; or ● Reviewing goals and objectives and measuring progress toward these goals. HIP may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Page 6 Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Separate Account Managers - HIP may select one or more Separate Account Managers (each, a “Manager”) through a wrap program sponsored by Raymond James & Associates member New York Stock Exchange/SIPC (the “Raymond James Wrap Program”) to act as a sub-adviser for Client accounts. HIP’s access to various Managers allows HIP to offer a wide variety of manager styles, and provides the opportunity to utilize more than one Manager. Factors that HIP considers in recommending/selecting a Manager for a client account generally include the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research. The Manager(s) generally will be granted discretionary trading authority to provide investment supervisory services for the portfolio. In most cases, HIP retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent. HIP will monitor the investment approach and performance of the Manager(s). C. Client Account Management Prior to engaging HIP to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – HIP, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – HIP will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – HIP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – HIP will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs HIP does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by HIP. E. Assets Under Management As of December 31, 2023, HIP manages $502,784,870 in Client assets, $485,498,032 of which are managed on a discretionary basis and $17,286,838 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.