A. Management and Ownership. We are managed by Rege S. Eisaman, Michael Carlin, Mark E. Carr, Jeffrey S. Camp, David J. Janczewski, Jason Buck, Erik N. Larson, Nicholas Rounds, Bhavna Khurana, Shaunna Zoeckler, Drake Qualls and Forrest Sumlar (“IOC Principals”), pursuant to a management agreement between Blue Hawk, LLC (“Blue Hawk”) and IOC. The IOC Principals serve as leaders and officers of IOC and are responsible for the management, supervision and oversight of IOC. FOCUS FINANCIAL PARTNERS, LLC IOC is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, IOC is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because IOC is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of [Partner Firm]. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. B. Services Offered. We provide wealth management and portfolio management investment advisory services to clients who are primarily high net worth individuals, trusts, charitable and non-profit organizations, individuals (other than high net worth individuals), corporations and other investment advisers. Some clients engage us to provide holistic financial planning and wealth management advice and asset allocated portfolio management services. We typically invest the assets of such clients in equity securities of individual companies, equity options, exchange- traded funds, laddered portfolios of individual bonds, bond funds and private investments. Some clients invest in the proprietary equity and income portfolio management strategies we offer. These strategies currently include:
• A large capitalization equity portfolio which typically holds 25-35 equity securities;
• An equity income strategy which typically holds 25 to 35 stocks and generates income by selling covered calls or writing puts secured by cash;
• Equity hedge strategies which hold active or passive long positions and broader short market positions;
• A global ETF portfolio which typically holds 20 to 35 positions; and
• A tactical diversifying portfolio which currently contains ETFs that are invested in commodities, foreign currencies, bonds and funds holding domestic and/or global securities, but the holdings and exposures are unconstrained and can be changed relatively quickly. Some clients will engage us to allocate assets to one or more outside portfolio managers to manage all or certain portion of the client’s portfolio based on how their investment styles align with the client’s objectives and preferences. In deciding which third-party managers to allocate client assets to for management, we will work with Springtide Partners (“Springtide”) to evaluate and monitor the performance of the third-party managers. If we determine that one or more of the third-party managers are no longer suitable for one or more clients, we will remove the corresponding assets from the third- party manager’s management and will reallocate those assets to

suitable third-party managers as appropriate. We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. We have come by some client relationships directly and other relationships by way of referrals or arrangements with unaffiliated financial institutions. In particular, many clients are referred to us through the Schwab Adviser Network. We also serve as a subadviser in the Aintree Capital Private Manager Program, and receive a portion of the advisory fees charged by the institutional manager for its investment management services. These programs have varying fee arrangements and may be offered on a wrap fee basis. We gladly welcome clients from any source. We also offer consulting services to employers (“Plan Sponsors”) sponsoring employee retirement plans (“Plans”). We assist Plan Sponsors and their Plans’ trustees and other named fiduciaries by providing a variety of services including, but not limited to:
• Investment policy statement review;
• Designated Investment alternatives;
• Qualified default investment alternatives;
• Third-party advisors and managers advice;
• Administrative support;
• Investment support;
• Oversight of relationship with service provider; and
• Participant services IOC is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including plan participants. IOC is also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, IOC is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. C. Customization and Client Restrictions. Clients can engage us as a wealth manager, to provide portfolio management services, or in a manner combined and customized to meet client needs. We will generally accept reasonable client restrictions with respect to securities held in client accounts. We will also generally accept restrictions on the ownership of certain types of securities and the use of margin, options, and other account features. D. Wrap Fee Programs. Adviser has no information applicable to this item. E. Assets Under Management. As of December 31, 2023: Total Assets Under Management $ 5,814,389,451 Discretionary Basis $ 5,183,607,319 Non-Discretionary Basis $ 630,782,132