A. General Description of Advisory Firm Eaglebrook was founded in April 2019, commenced operations in 2019 as a state registered investment adviser; and registered effective 2021 as an investment adviser with the United States Securities and Exchange Commissions (the “SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”). Christopher King is the founder and CEO of Eaglebrook, as well as the principal owner of Eaglebrook. Throughout the Brochure, you will see the words “we,” “us,” “our,” “the Firm,” “our Firm” or “Eaglebrook.” Where you see these words, the Brochure is describing products and services provided by Eaglebrook Advisors, Inc., or by employees, supervised persons and Access Persons of Eaglebrook. An “Access Person” is an employee or independent contractor who has been determined by Eaglebrook to be governed by the Eaglebrook Code of Ethics. See Item 11, Code of Ethics, for additional information regarding the Eaglebrook Code of Ethics, which governs personal trading by Access Persons. Where you see the words “you” and “your,” the Brochure is describing our clients and prospective clients. We publish additional information about our business on our website at https://www.eaglebrook.com/. B. Description of Advisory Services Eaglebrook provides Investment Advisors (“Advisors”) the ability to invest their clients’ directly into digital assets through the use of Eaglebrook’s proprietary separately managed account investment platform which allows for client onboarding via an advisor portal (the “Advisor Portal”), and the delivery of various digital asset investment models and allocation modules, execution of transactions in digital assets and the integration and reporting of holdings and trade information to Advisor’s portfolio management system. Our clients are Advisors and their respective clients (“Clients”). Eaglebrook provides high-net worth or sophisticated clients (collectively “Direct Clients”) the ability to invest directly into digital assets through the use of Eaglebrook’s proprietary separately managed account investment platform which allows for Direct Client onboarding via the Client Portal (“Client Portal"), and the delivery of various proprietary and third-party digital asset investment models (together and each a “Model”) and allocation modules, execution of transactions in digital assets and the integration and reporting of holdings and trade information to the Direct Client or to a third party representative identified to Eaglebrook by the Client (each, a “Representative”) via the Direct Client/Representative portal (the “Direct Client/Representative Portal”). Together, the Advisor Portal, the Client Portal and the Direct Client/Representative Portal are referred to as the “Investment Platform.” Direct Clients are included within the definition of Client for purposes of this ADV. “Digital assets” includes cryptographically derived assets, referred to as cryptoassets, cryptocurrencies, and/or blockchain tokens, virtual currencies or digital currencies, such as bitcoin and ether, as well as other assets available on public, private or permissioned blockchains and/or ledger systems, including decentralized application tokens and protocol tokens, and other digital assets that are based on a cryptographic protocol of a computer network that can be (i) centralized or decentralized, (ii) closed or open-source, and/or (iii) used as a medium of exchange, store of value, and/or represent ownership in some asset, interest or object, whether real or intangible. Digital assets are a digital representation of value that function as a medium of exchange, a unit of account, or a store of value, but they do not have legal tender status in the United States. Digital assets are not backed nor supported by any government or central bank (except for Central Bank Digital Currencies (“CBDCs”)). The prices of digital assets are derived by market forces of supply and demand, and digital assets are more volatile than traditional currencies and financial assets. Most of Eaglebrook’s Clients’ digital assets are currently invested in bitcoin and ether; however, other digital asset holdings in Client accounts are anticipated to grow and Models offer holdings other than bitcoin and ether. Bitcoin is a type of digital asset where balances are only kept on a distributed ledger designed for public transparency and bitcoin transactions are verified by computing power. Bitcoin is not issued or backed by any banks or governments, nor is an individual bitcoin valuable as a commodity. Despite it not being legal tender in most parts of the world, bitcoin is popular and has triggered the launch of thousands of other cryptocurrencies. Ethereum is a blockchain platform which hosts several digital assets, including ether. As a blockchain network, Ethereum is a distributed ledger for verifying and recording transactions. The network's users can create, publish, monetize, and use applications on the platform, and they use its digital assets, including ether as payment for those network services. The Investment Platform is a technology platform which operates like a traditional trade execution system and allows Advisors to open a Separately Managed Account (“SMA”) on behalf of each of their Clients and to place digital asset trades for their Clients in their SMAs which are routed directly to a digital asset exchange for execution and processing, as well as for Direct Clients to open a SMA and to place trades for digital assets in their SMAs which are routed directly to one or more digital asset exchanges for execution and processing. The Investment Platform provides transactional reporting of the Client’s digital assets in the SMA which can be integrated into the Advisor’s or Representative’s third-party performance reporting system and used by the Advisor or Representative for their Client communications and overall performance reporting to their Clients. Because the Investment Platform integrates with various industry-standard portfolio management and reporting systems, Advisors and Representatives can see each of their Client’s digital asset exposures directly in the portfolio management system alongside the client’s other asset holdings. Advisors and Representatives can also view their Client’s holdings, transactions, Client documents, research, and educational materials directly by logging into the lnvestment Platform. The Investment Platform allows Clients and/or Advisors and Representatives, on behalf of their Clients, to open accounts directly with a digital asset custodian. Available custodians for Eaglebrook clients are currently Gemini Trust Company, LLC (“Gemini”), a custodian qualified under New York Banking Law and licensed by the New York State Department of Financial Services (“NYDFS”) and Anchorage Digital Bank “Anchorage”, a custodian chartered by the Office of Comptroller of the Currency. In the future, other digital asset custodians may be available. The Investment Platform integrates with the digital asset custodian to allow Advisors and Representatives, on behalf of their Clients, and Direct Clients, to add funds or in-kind contributions, withdraw funds, enter orders to purchase and sell digital assets, build a custom allocation module and/or make investment selections of various third-party investment models, as more fully described below, directly in the Investment Platform. Details regarding the custody and exchange services provided by Gemini and Anchorage are discussed below in Item 8, Item 10, Item 12, and Item 15. Eaglebrook also has legacy investment management agreements that were entered into directly with individual Clients and which do not specifically name any Advisor as an interested party. We no longer enter into such agreement types and instead enter into Tri-Party Agreements which are among the Investment Advisor, Client and Eaglebrook or Investment Platform Agreements that are directly between the Direct Client and Eaglebrook. All Investment Platform Agreements with Direct Clients are non-discretionary. Our investment advice is limited to digital assets. We do not provide investment advice regarding any other type of assets (e.g., traditional stocks, bonds, registered investment companies, private funds). Digital Asset Investment Module and Digital Asset Models Custom Allocation Module The Client or Advisor, on behalf of the Client, may elect to construct a custom allocation of certain digital assets. The Advisor typically has full discretionary authority over the investments and transactions involving the assets allocated to that Custom Allocation Module and may trade the account without the prior consent of the Client on each trade. The Advisor is typically responsible for selection and maintenance of the custom allocation and Eaglebrook will execute all transactions for Client assets according to the Advisors direction. Digital assets available for purchase and sale using the Custom Allocation Module are limited only to those digital

assets that the Client’s respective digital asset custodian offers on its exchange platform, which is subject to change at any time as digital asset custodians may delist assets from trading with or without notice to Eaglebrook. Third Party Models Third-Party Models are developed by unaffiliated institutional firms, which currently include Franklin Templeton, ARK Invest, Bitwise, Exos Asset Management, Arbor Digital, among others (“Model Providers”). Other Model Providers may be added or removed from time to time. Eaglebrook has selected these Model Providers for the purpose of making the Third-Party Models available on the Investment Platform for distribution to Advisors and Clients. Advisors and their respective Clients will enter a Tri-Party Agreement directly with Eaglebrook which will allow Advisors access to the Investment Platform for purposes of investing Clients into digital assets using the Models provided. The Model Provider is responsible for development and maintenance of the Third-Party Model through rebalancing of digital holdings and weights that the Model Provider believes is most appropriate for the model pursuant to the model’s stated investment strategy. It is the responsibility of Eaglebrook to maintain and rebalance the holdings and weights of the Third-Party Models when Eaglebrook receives rebalance instructions from the Model Provider. While Models are provided by Eaglebrook, the Advisor decides the amount of their Clients’ assets to be invested and selects the Model or custom digital asset allocation that is most appropriate for their Client. Similarly, each Direct Client decides the amount of assets to invest and selects the Model or custom digital asset allocation that it believes is most appropriate for itself. See additional information regarding discretion and suitability in Item 16, Investment Discretion, below. Models may change from time to time and Models can be discontinued, changed, or replaced by Eaglebrook. Digital assets available for purchase and sale within the Models are limited to only those digital assets that the digital asset custodian offers on its exchange platform, which may be subject to change at any time with or without notice to Eaglebrook. Model Providers do not consider the investment objectives, needs or restrictions of any Client when developing their Models and as such the Advisor and the Client have the ultimate responsibility for suitability determinations on whether any Third-Party Model is appropriate for the Clients’ needs and risk tolerance. Proprietary Models Eaglebrook may develop and provide proprietary digital asset allocation models, and such “Proprietary Models” may be made available to Advisors and Clients on the Investment Platform. Such Proprietary Models are managed according to the stated investment objective of the Proprietary Models and are not developed or managed to any Client or Client type. Eaglebrook does not consider the investment objectives, needs or restrictions of any Client when developing Proprietary Models and as such the Advisor and the Client have the ultimate responsibility for suitability determinations on whether any Proprietary Model is appropriate for the Clients’ needs and risk tolerance. Tax Loss Optimization Some digital assets such as bitcoin and ether are treated for tax purposes as property and as such, the wash-sale rule presently does not apply, but that may be subject to change. Because these assets are treated for tax purposes as property, general tax principles applicable to property transactions apply with equal force to digital asset transactions. Eaglebrook offers a tax-loss optimization tool that gives Advisors and/or Clients the ability to establish account parameters to allow Clients to time the sale of a particular digital asset at a pre-determined loss threshold and enter a transaction for the subsequent purchase of a digital asset after harvesting a tax loss. Tax-loss optimization parameters are established at the discretion of the Advisor and/or Client. When tax-loss optimization is selected by the Advisor for the Client, the Advisor is instructed to select tax-loss optimization parameters, including allocation method (such as highest in, first out “HIFO” or lowest in, first out “LIFO”) and establishes a threshold loss for when the automated tax-loss optimization will be triggered. The Investment Platform manages the tax-loss optimization per the Advisor and Client instructions. The Advisor and/or Client determine when assets in a Client account should be bought or sold. Eaglebrook does not determine the tax-loss optimization parameters for Clients. Tax savings will vary from Client to Client. Eaglebrook provides the tax-loss optimization tool that processes tax-loss trades and reporting of tax losses, however, the determination of whether a Client will use such losses for purposes of reducing the Client’s tax burden is made solely by the Client in consultation with Client’s tax consultant or advisor, such as Client’s certified public accountant (“CPA”) or tax attorney. Eaglebrook does not provide legal or tax advice nor is Eaglebrook licensed to do so. The offer of the tax-optimization tool should in no way imply that the process of selling digital assets at a loss and subsequently purchasing is permitted by IRS rules generally or the “wash sales” rule specifically. Clients are urged to consult their tax consultants or advisors/CPAs or tax attorneys for advice on taxability of digital assets. Or, for more information on the tax treatment of property transactions, please see www.irs.gov, where the Internal Revenue Service provides several publications, including Notice 2014-21 and Publication 544, Sales, and Other Dispositions of Assets. Tax laws and regulations are complex and subject to change, which can materially impact investment results. Eaglebrook cannot guarantee and makes no warranties with regard to the results obtained by the use of the tax- loss optimization tool and disclaims any liability arising out of the use of, or any tax position taken in reliance on, such information, including whether the IRS will allow such losses. Factors that could impact the value of any tax loss optimization efforts include market conditions, the tax characteristics and IRS treatment of digital assets held in the account, client-imposed investment restrictions, client tax rate, and any tax law changes. Digital assets contributed to an account may be sold for a taxable gain or loss at any time. No investment strategy or risk management technique can guarantee returns or eliminate risk in any market environment. Changes in laws and regulations may have a material impact on the permissibility of tax-optimized investing and on pre and/or after-tax investment results. Eaglebrook can make no guarantees as to the effectiveness of tax- optimized investing techniques applied in serving to reduce or minimize a client’s overall tax liabilities or the tax results that may be generated by a given transaction and as stated, nor does Eaglebrook that losses will be allowed by the Internal Revenue Service. Eaglebrook does not provide tax or legal advice. Please consult with a tax professional to determine whether the tax-loss optimization tools provided meet Internal Revenue Service requirements. Tax-loss optimization is available only for holdings of bitcoin and ether and therefore may not be available for certain Custom Allocations Modules or Third-Party Models. Education and Research Eaglebrook provides research and education about the digital assets market which is primarily made available directly on the Advisor Portal. Certain education and research materials are publicly available on the Eaglebrook website. Eaglebrook will also provide research and market commentary to clients and the public generally. C. Our Clients Our Clients are Advisors and their respective Clients. As noted above, in some cases, we may allow individual high net worth or sophisticated investors who are not themselves clients of an Advisor to have direct access to the Investment Platform, i.e., Direct Clients. In such cases, the individual Direct Client will enter into a non-discretionary investment management agreement with Eaglebrook, and we will assist the individual Direct Client to open an account on the Investment Platform. In such cases, we may also advise the Direct Client on the digital asset allocation, but the individual high net worth investor ultimately determines the digital assets to purchase. The Direct Client may use the Custom Allocation Module to select a custom allocation the Direct Client desires or may invest in Third-Party Models or Proprietary Models, if any, offered. D. Wrap Fee Programs. We do not currently participate in any Wrap Fee Programs. E. Assets under Management (“AUM”) As of March 1, 2024, we managed approximately $211,105,885 in non-discretionary assets under management.