A. Firm Information Vanquour LLC (“Vanquour” or the “Adviser”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). Vanquour is organized under the laws of the State of New York. Vanquour was founded in November 2021. Vanquour is owned and operated by Lu Zhou, who is the President and Chief Compliance Officer of Vanquour. B. Advisory Services Offered Vanquour offers investment management services to individuals, high net worth individuals, families, trusts, estates, businesses and retirement plans (each referred to as a “Client”). Investment Management Services Vanquour provides customized investment management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Vanquour works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Vanquour will then construct an investment portfolio, primarily consisting of diversified mutual funds, exchange-traded funds (“ETFs”), individual stocks, and individual bonds to achieve the Client’s investment goals. Vanquour may also utilize covered options, managed account programs offered by the Client’s custodian (“Custodian”) (please see Independent Managers disclosure below) and/or other types of investments, as appropriate to meet the needs of the Client. Vanquour may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations. Vanquour’s investment strategies are primarily long-term focused, but Vanquour may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Vanquour will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by Vanquour. Vanquour evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Vanquour may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Vanquour may recommend specific positions to increase sector or asset class weightings. Vanquour may recommend employing cash positions as a possible hedge against market movement. Vanquour may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. 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. Use of Independent Managers - Vanquour may recommend that a Client allocate a portion of their investments to one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) available through the Custodian’s platform. The Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services, including discretionary management and fee billing. Vanquour will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. Vanquour will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. Financial Planning Services Vanquour will typically provide a variety of financial planning and consulting services to Clients. 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 or consulting may encompass one or more areas of need, Page 5 including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Vanquour may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, Vanquour will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, Vanquour 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. Financial planning and consulting recommendations pose a conflict between the interests of Vanquour and the interests of the Client. For example, Vanquour has an incentive to recommend that Clients engage Vanquour for investment management services or to increase the level of investment assets with Vanquour, as it would increase the amount of advisory fees paid to Vanquour. Clients are not obligated to implement any recommendations made by Vanquour or maintain an ongoing relationship with Vanquour. If the Client elects to act on any of the recommendations made by Vanquour, the Client is under no obligation to implement the transaction through Vanquour. Retirement Plan Advisory Services Vanquour provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). Vanquour’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance These services are provided by Vanquour serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Vanquour’s fiduciary status, the specific services to be rendered and all direct and indirect compensation Vanquour reasonably expects under the engagement. Page 6 C. Client Account Management Prior to engaging Vanquour to provide investment management services, each Client is required to enter into one or more agreements with Vanquour that define the terms, conditions, authority and responsibilities of Vanquour and the Client. These services may include:
• Establishing an Investment Strategy – Vanquour, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Vanquour 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 – Vanquour will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Vanquour will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Vanquour does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of March 31, 2024, Vanquour had $66,400,000 in regulatory assets under management, all of which are managed on a discretionary basis.