ASM, a New York Limited Liability Company, was founded in February of 1982 and is wholly owned by its parent Atalanta Sosnoff Capital, LLC (“ASC”). ASM is a registered investment adviser dedicated to providing quality, investment management services to its clients. ASC is a registered investment adviser retained by ASM as the sub adviser on all of its clients’ accounts. All investment decisions, including broker- dealer selection, made on behalf of ASM's client accounts are made or given by members of ASC’s Investment Committee and Fixed Income Committee. ASM provides investment advisory services on a discretionary basis to separately managed accounts including individuals, trusts, tax exempt funds (such as pension, annuity and profit-sharing plans), charitable organizations (such as endowments and foundations), State and Municipal government entities and corporations. The investment advisory services are provided based on written agreements between the client and ASM. The investment advisory services include, without limitation, management of equity, balanced and fixed income portfolios. These services are provided by ASM based on the client's financial goals and objectives which are provided by the client. ASM provides investment advisory services as a sub advisor to independent registered investment advisors (IRIA) whereby ASM will enter into an agreement with the IRIA to provide discretionary investment advisory services to the IRIA clients. ASM is a sub advisor to the following IRIAs: Lockwood Advisors Inc., Stolper & Company, and HighTower. The IRIA recommends ASM as the investment advisor to their client account. IRIA clients should be aware that ASM will not be provided with sufficient information by the IRIA to perform an assessment as to the suitability of ASM’s services for the client. ASM will rely on the RIA who, within its fiduciary duty, must determine the suitability of ASM’s services for the client. ASM serves as a portfolio manager in a number of wrap fee programs. The list of programs includes, but is not limited to, LPL’s Manager Select; Morgan Stanley Wealth Management CES and IMS; Oppenheimer’s STAR; Envestnet PPS; RW Baird’s Advisory Choice; Wells Fargo Advisor Network; Wedbush Securities MAP; UBS ACCESS, SWP and MAC; Stifel Nicolaus SMAP; DA Davidson MAC; TD Ameritrade MAN; Fidelity Dual; Raymond James OSM; Janney Montgomery Scott SMA; Lockwood SMA; and Hightower Advisor Direct. These wrap fee programs are arrangements in which investment advisory services, brokerage execution services and custody are provided by a sponsor (“Wrap Program Sponsor”) for a single predetermined “wrap” fee (regardless of the number of trades executed by a client). Generally, clients participating in a wrap fee program (“Wrap Program Clients”) pay this single, all- inclusive fee quarterly in advance to the program sponsor, based on the net assets under management. ASM receives from the Wrap Program Sponsor a portion of the wrap fee for the portfolio management services it provides. Restrictions for client accounts in the wrap programs are monitored primarily by the sponsors. ASM provides investment advisory services in the form of a model portfolio to be utilized by a sponsor bank and/or broker dealer in an overlay program. Under the unified managed account (UMA) programs, ASM has an agreement with the sponsor (“UMA Program Sponsor”) and does not have any contact with the end clients (“UMA Program Clients”). ASM participates in UMA programs with the following financial institutions: CitiPrivate Bank UMA, Morgan Stanley Wealth Management Select UMA, Envestnet, Stephens Inc., Wells Fargo Masters & DMA, Janney Montgomery Scott UMA, FolioDynamix, Stifel, Adhesion, LPL MWP, Manager Select, Manager Access Select, and Oppenheimer UMA. Under these UMA programs, the UMA Program Sponsor receives ASM’s model portfolio and, based upon the model, the UMA Program Sponsor executes the model changes for each UMA Program Client’s portfolio. ASM provides model portfolio to other UMA Programs whereby the UMA Program Sponsor executes portfolio transactions for UMA Program Clients based on the UMA Program Sponsors’ own investment discretion. ASM classifies these assets as “assets under advisement” and does not include the assets in its assets under management on Form ADV Part 1. Restrictions for client accounts in the UMA Programs are monitored entirely by the Sponsors. Wrap Program Clients and the UMA Program Clients are responsible for

evaluating whether the fee paid to the Wrap Program or UMA Program Sponsor exceeds the cost for the same services if such services were provided separately. Wrap Program and UMA Program Clients should consider the overall fees and the services received to determine if the product is appropriate. Due to the structure of most wrap and UMA programs, ASM does not provide the same level of client relationship services to Wrap or UMA Program Clients as it does to other clients. Each Wrap and UMA Program Sponsor has their own brochure which contains detailed information about its wrap fee program, including the wrap fee charged. Copies of each brochure are available from the Wrap and UMA Program Sponsor upon request. Each Wrap and UMA Program Sponsor has retained ASM through a separate investment advisory contract. Wrap Program Clients should note that ASM may execute transactions for their accounts through the Wrap Program Sponsor. Transactions for Wrap Program clients may be executed away from the Wrap Sponsor if execution prices are favorable, and a portion of the client commission may be used for soft dollar research costs. In this instance the Wrap Program Client will incur additional execution costs but may receive more favorable execution prices. During calendar year 2023, excluding UMA programs, ASM executed less than 5% of Wrap Program Client transactions away from the applicable Wrap Sponsor. Transactions executed through a Wrap Sponsor may be less favorable in some respects than ASM’s clients whose trades are not executed through the Wrap Sponsor. ASM may be constrained in obtaining best execution for Wrap Program Clients by routing trades to the Wrap Sponsor. However, ASM will make every effort to obtain best execution within any constraints that may be set forth by Wrap Program Clients and the Wrap Program Sponsor. Wrap Program Clients should also be aware that ASM will not be provided sufficient information by the Wrap Program Sponsor to perform an assessment as to the suitability of ASM’s services for the client. ASM will rely on the Wrap Program Sponsor who, within its fiduciary duty, must determine not only the suitability of ASM’s services for the client, but also the suitability of the wrap fee program for the client. ASM provides investment advisory services to numerous separately managed accounts that have substantially similar investment objectives and similar portfolio holdings and characteristics. However, ASM clients having substantially similar investment objectives will not have identical investment portfolios. Differing investment portfolios can be expected to result from several factors, including, without limitation, the following: regulatory constraints that apply to certain accounts but not to others; investment constraints imposed by the client; and the amount of cash available for investment at certain times. As a result, accounts may have a different investment portfolio and different performance results than other accounts even though the accounts have identical or substantially similar investment objectives. In addition, there may be circumstances when one account will sell a security while another account may purchase the security on the same day primarily due to cash contributions and/or withdrawals. A small number of ASM's accounts, including accounts owned by its employees, their families, close associates and certain charitable organizations are managed without a management fee and/or, in certain cases, under special arrangements in which the client continues to exercise investment authority over their account. In addition, a small number of discretionary account clients also maintain non-discretionary accounts in which the clients make their own investment decisions without any investment advisory services provided by ASM or ASC investment personnel. The non-discretionary client accounts use ASM to communicate trade orders to the custodial broker dealer on their behalf. ASM and ASC do not receive any compensation from these non-discretionary accounts. ASM and ASC employees and their families will participate in bunched orders with the Firm’s client accounts at an average price if it is beneficial to the client to do so subject to the Company’s Code of Ethics. As of December 31, 2023, ASM managed $2,856 million on a discretionary basis on behalf of approximately 482 clients and provides investment advisory advice to an additional $396 million on behalf of 5 UMA relationships.