Firm Overview FESAM is a limited liability company organized under the laws of the State of Delaware and began operations as a registered investment adviser under the Advisers Act in 2020. It is a wholly owned subsidiary of First Eagle Investment Management, LLC (“FEIM”) and an indirect subsidiary of First Eagle Holdings, Inc., a holding company incorporated in Delaware (“FE Holdings” and the advisory business of FEIM, FESAM and all other affiliates, “First Eagle”). Since 2015, a controlling interest in FE Holdings has been owned by BCP CC Holdings L.P., a Delaware limited partnership (“BCP CC Holdings”). BCP CC Holdings GP L.L.C., a Delaware limited liability company (“BCP CC Holdings GP”), is the general partner of BCP CC Holdings and has two managing members, Blackstone Capital Partners VI L.P. (“BCP VI”) and Corsair IV Financial Services Capital Partners L.P. (“Corsair IV”). BCP VI is indirectly controlled by a public company, Blackstone Inc. (NYSE: BX) (“Blackstone”). Corsair IV is indirectly controlled by Corsair Capital LLC (“Corsair”). The general partner of Corsair IV is Corsair IV Management L.P., whose general partner is Corsair, the sole member of which is Corsair Capital, L.P., whose general partner is Corsair Capital Group, Ltd., of which the controlling member is D.T. Ignacio Jayanti. Investment vehicles indirectly controlled by Blackstone and Corsair and certain co-investors own a majority economic interest in FE Holdings and FEIM through BCP CC Holdings, and therefore indirectly in FESAM, through BCP CC Holdings. Investment Advisory Services FESAM provides investment management services to wrap fee programs sponsored by broker-dealers, banks, or other investment advisers (“Wrap/SMA Programs”). In most Wrap/SMA Programs, the program sponsor (“Sponsor”) charges participants (“participants” or “investors”) a comprehensive fee (the wrap fee), inclusive of the advisory fee charged by FESAM and fees for other services provided by the Sponsor, including typically trading commissions for securities transactions executed through the Sponsor or a designated broker (“Designated Broker”). Additional fees may be incurred in connection with certain trades, if any, instructed by FESAM on behalf of the accounts. Wrap/SMA Programs vary by Sponsor, and FESAM may act in a discretionary or non-discretionary capacity. Under a single contract Wrap/SMA Program or a “model-only” Wrap/SMA Program, FESAM enters into an investment management agreement directly with the Sponsor, while under a dual contract Wrap/SMA Program, FESAM enters into an investment management agreement with each underlying program participant. For discretionary Wrap/SMA Programs, FESAM has the authority to enter into transactions on behalf of Wrap/SMA Program participants, subject to any investment or trading restrictions provided by the Sponsor or Wrap/SMA Program participants. Under its discretionary Wrap/SMA Programs, FESAM supports the program’s eligibility for an exemption from the definition of an “investment company” pursuant to Rule 3a-4 under The Investment Company Act of 1940, as amended (the “Investment Company Act”). See Item 12 — Brokerage Practices below for additional information about trade execution under a Wrap/SMA Program. Investment decisions are based on the chosen investment strategy, in line with any applicable guidelines and/or restrictions. For separately managed account (“SMA”) programs, FESAM has agreed to abide by certain restrictions from investors, including but not limited to restrictions on securities or types of securities. In FESAM’s management of an investor’s account, FESAM will typically not be responsible for and will not consider any securities, cash or investments owned by the investor, the investor’s financial circumstances or investment objectives outside of the investor’s assets managed by FESAM. Depending on the program terms, a participant in a Wrap/SMA Program may restrict the purchase of certain securities for an account. An investor and/or a Sponsor may name either specific securities or a category that includes specified securities that may not be purchased for the account. The investor or Sponsor is responsible for identifying any security or group of securities which may not be held in the account. If an investor identifies a category of restricted securities (e.g., tobacco companies, gambling stocks) without identifying the underlying companies of which the category is comprised or a source for identifying such underlying companies, FESAM or the Sponsor may utilize outside service providers to identify the universe of companies that is considered in such a category. For

instance, under FESAM’s current protocols, a prohibition on issuers engaged in a particular type of activity or business (e.g., the distribution, manufacturing, supply, production, provision, or retail sales of, or other involvement in, a certain category of restricted services or products, such as alcohol) will typically result in the restriction of the securities of an issuer if such issuer derives at least a minimum percentage (e.g., 10%) of its revenue, or of some other metric of economic exposure, from the designated activity or business. As a result, an investment restriction with respect to a specific activity or business type does not mean that FESAM’s investor will eliminate all indirect exposure to that activity or business, but rather that the investor’s account will exclude investments into issuers that are deemed by a third-party data provider to exceed a pre-established minimum economic involvement in that activity or business. When a security is required to be sold or is restricted from being purchased for Form ADV Part 2A Brochure page 5 First Eagle Separate Account Management, LLC an account, it may adversely affect the account’s performance and cause it not to track the performance of FESAM’s other accounts without similar restrictions within the same investment disciplines. The change of the classification of a company, the grouping of an industry or the credit rating of a security may force FESAM to sell securities in an investor’s account at an inopportune time and possibly cause a taxable event to the investor. FESAM manages the following principal investment strategies:
• Overseas ADR — This strategy seeks to deliver attractive real returns while avoiding the permanent impairment of capital over time by using a value approach to investing in mainly equity securities issued by non-U.S. corporations primarily through USD tradeable securities, a majority of which are American Depositary Receipts (“ADRs”). The investment team seeks to follow a bottom-up, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability, trading at what they believe are significant discounts to their Intrinsic Values.1 The non-U.S. equity strategy may be invested in companies located in mature (also known as developed) markets or in emerging markets. The investment team also invests in exchange-traded funds (“ETFs”) representing exposure to gold and other precious metals. Additionally, the investment team has the flexibility to invest in U.S. traded stocks of non-U.S. companies and U.S. companies engaged in significant non-U.S. business, and cash and cash equivalents.
• US Smid Cap Opportunity — This strategy seeks long-term growth of capital by investing in equity securities of small- and midcap companies in an attempt to take advantage of what the team believes are opportunistic situations for undervalued securities. The team seeks to invest in small and midcap companies that have become disconnected from their normalized valuations and have an identifiable catalyst for improvement and positions the team to capture the evolution of quality businesses as they grow.
• Global SMA — This strategy seeks to deliver attractive real returns while avoiding the permanent impairment of capital over time by using a value approach to investing mainly in equity securities issued by U.S. and non-U.S. corporations through USD tradeable securities, including ADRs. The investment team seeks to follow a bottom-up, fundamental approach, focusing on companies with businesses that they believe have sustainable profitability, trading at what they believe are significant discounts to their Intrinsic Values. The strategy may be invested in companies located in mature (also known as developed) markets or in emerging markets (including frontier markets, a sub-sector of emerging markets). The investment team also invests in ETFs that allocate to gold and other precious metals.
• Rising Dividend SMA — FESAM’s Rising Dividend SMA Strategy seeks capital appreciation and current income by investing primarily in domestic stocks. Normally, the strategy’s assets will be invested primarily in domestic equity and debt instruments. Such investments include common stock, hybrid instruments such as preferred stock and convertible securities and real estate investment trusts. At least 65% of the strategy’s net assets will be income-producing. Assets under Management/Assets under Advisement As of December 31, 2023, our discretionary, regulatory assets under management were $261,106,868 and our non-discretionary assets under advisement were $ 1,059,115,430.