D.A. Davidson & Co. ("D.A. Davidson", the “Firm”, or “we”), established in 1935, is a dually registered investment adviser and broker-dealer with its principal place of business located in Great Falls, Montana. The firm is a wholly owned subsidiary of D.A. Davidson Companies, a financial services holding company. D.A. Davidson offers the following investment advisory services: x Wrap Fee Programs where we act as a portfolio manager and/or sponsors of several wrap fee programs for a fee as described in a separate brochure, called the “Wrap Fee Program Brochure”. The Wrap Fee Program Brochure provides details on the wrap fee programs and services. Client may obtain a copy of that brochure by contacting a Financial Advisor, by mailing a request to 8 Third Street North, Great Falls, MT 59401, Attn: Compliance Department, or by calling 406-727-4200 or 800-332-5915. Client may also obtain a copy of that brochure and other important disclosures online at dadavidson.com/Disclosures. x Equity Research Services where we offer equities-based research reports and other research-related communications to institutional clients as described in a separate brochure, called the “Equity Research Services Brochure.” The Equity Research Services Brochure provides details on these services. Client may obtain a copy of that brochure by contacting a Financial Advisor, by mailing a request to 8 Third Street North, Great Falls, MT 59401, Attn: Compliance Department, or by calling 406-727-4200 or 800- 332-5915. Client may also obtain a copy of that brochure and other important disclosures online at dadavidson.com/Disclosures. x Retirement Plan Services where we provide advice services to plan sponsors, pooled accounts, and participants, which are described further in this ADV 2A Firm Brochure (the “Brochure”). x Financial Planning Services where we provide financial plans both for a fee and for no additional cost, which are described further in this Brochure. x Davidson Private Wealth Services, where we provide financial plans and other related services for no additional cost to clients with more than $20 million in stated net worth, which are described further in this Brochure. x Advisory Services to the Concordant Fund where we provide advisory services to a private fund offered to sophisticated qualifying investors, which are described further in this Brochure. All discussions of The Concordant Fund in this Brochure, including, but not limited to, its investments, the investment strategies implemented on behalf of The Concordant Fund, the fees and other costs associated with an investment in The Concordant Fund, and conflicts of interest inherent in D.A. Davidson’s management of The Concordant Fund, are qualified in their entirety by reference to The Concordant Fund’s confidential private placement memorandum and governing documents (referred to collectively as the “Concordant Fund Offering Documents”). The information contained in this Brochure is concerning the fees, conflicts of interest and other information clients should consider with regard to the Financial Planning Services, Retirement Plan Services and Advisory Services to the Concordant Fund. It is current as of the cover date and is subject to change at D.A. Davidson’s discretion. Clients should retain this Brochure for their records. Clients are encouraged to carefully consider the differences between brokerage and investment advisory services including D.A. Davidson’s obligations, costs, and the need for the services provided. For additional information, please review the Firm’s Form Client Relationship Summary (“Form CRS”), which provides information about the differences between brokerage accounts and advisory accounts. Generally, the Firm and its Financial Advisors have an incentive to recommend investment advisory accounts over brokerage accounts because the Firm and its Financial Advisor receive higher fees for advisory accounts than brokerage accounts, and higher fees for some advisory programs than others. The Firm requires its financial professionals to consider a number of factors when recommending an account type, or change in account types, including, but not limited to, the clients Investment Profile (as defined below); whether client is tax- sensitive and needs professional tax-management solutions; client’s investment experience and/or engagement level (i.e., desire and availability to be involved and informed on investment decisions); and client’s anticipated frequency of trading. This is intended to help ensure that the Firm’s account type recommendations to clients are reasonably expected to be cost-effective choices in light of their investment services and needs. Additionally, the Firm does not impose requirements on how many accounts a financial professional must have that are brokerage accounts or advisory accounts, nor incentivize the decision through its compensation. SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE Advisers Act Fiduciary Duty. As a registered investment adviser, D.A. Davidson is subject to a fiduciary duty under the Investment Advisers Act of 1940 (the “Advisers Act”), which includes both a duty of care and a duty of loyalty (referred to in this Brochure as the “Advisers Act Fiduciary Duty”). This means D.A. Davidson and D.A. Davidson’s registered investment advisor representatives (each, a “Financial Advisor,” and collectively, “Financial Advisors”) are required to act in the client’s best interest when providing advisory services, including those described in this Brochure. The duty of care requires, among other things, for D.A. Davidson and its Financial Advisors to seek best execution and to provide advice that is in the client’s best interest based on the client’s investment objectives, risk level, investment time horizon, financial information, and other circumstances (collectively, client’s “Investment Profile”) or mandate. The duty of loyalty requires D.A. Davidson to provide full and fair disclosure of, and obtain client’s consent to, conflicts of interest. The duties also require D.A. Davidson to monitor accounts when providing certain advisory services based on the terms of the agreement for that service between D.A. Davidson and a client. Special Rules for Retirement Accounts. When it comes to retirement and other qualified accounts, including employer-sponsored plans (“plans”), individual retirement accounts (“IRAs”), SEP IRAs, SIMPLE IRAs, Keogh plans, Coverdell educational savings accounts, and other similar accounts (collectively, “retirement accounts”) we are “fiduciaries” under Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (the “Code”), when we provide investment advice or manage a client’s account. ERISA and the Code limit the types of products and services D.A. Davidson can offer and provide with respect to retirement accounts. When making recommendations that clients open, rollover or transfer retirement account assets to an advisory account or change account types, the Firm relies on Prohibited Transaction Exemption (“PTE”) 2020-02, which allows D.A. Davidson, its financial professionals and affiliates to earn variable compensation for such recommendations subject to certain conditions. PTE 2020-02 requires D.A. Davidson to act in client’s best interest and not put their interest ahead of clients’ interests when providing these recommendations (“fiduciary acknowledgement”). Under the PTE 2020-02, D.A. Davidson and its financial professionals must also: x Meet a professional standard of care (give prudent advice); x Not put the Firm’s financial interests ahead of client’s (give loyal advice); x Avoid misleading statements about conflicts of interest, fees, and investments; x Follow policies and procedures designed to ensure that the Firm and its financial professionals give advice that is in client’s best interest; x Charge no more than is reasonable for the Firm’s services; and x Give the client basic information about conflicts of interest. This fiduciary acknowledgment does not create or modify a contractual obligation, or fiduciary status or obligations under state law. This fiduciary acknowledgement does not apply to federal, state, local, non-US or other types of workplace employee benefit plans that are subject to laws other than ERISA or Section 4975 of the Code. The above acknowledgement applies solely with respect to the following recommendations (“Covered Recommendations”), as may be applicable: x Roll Out Recommendations. From time to time, the Firm in coordination with client’s financial professional (and a centralized review team) will provide a written recommendation that client roll out assets from a plan to an IRA, from an IRA to a plan, or from a plan to a plan. x Account Type Recommendations at the Firm. From time to time, the Firm or client’s financial professional will recommend that client open a brokerage or advisory IRA, transfer money between brokerage and advisory IRAs, or transfer money from one wrap fee program or portfolio to another within an advisory IRA. Under the Firm’s wrap fee programs, the financial professional may recommend that client engage the services of an investment manager for their advisory IRA, which may include one of D.A. Davidson’s affiliates. The above acknowledgement does not apply to other suggestions, recommendations, and services the Firm and its financial professionals provide and are governed exclusively by the terms of clients’ other agreements with, and disclosures from, the Firm, as may be applicable. D.A. Davidson refers to these as “Excluded Recommendations and Transactions.” Excluded Recommendations and Transactions refer to communications that are not reasonably intended to be viewed or construed as an individualized/personalized suggestion for client to take a particular course of action with respect to their retirement accounts (“General Information and Education”) or that are otherwise not to be treated as Covered Recommendations under this disclosure, including, but not limited to: x General Information and Education about the financial markets, asset allocations, financial planning illustrations and the advantages and risks of particular investments; x General Information and Education materials about issues and alternatives that should be considered when deciding whether to roll out or transfer retirement account assets to the Firm; x Transfers of IRA assets held at a financial service company other than the Firm (including directly with an investment product sponsor); x Recommendations about investments in accounts that are not retirement accounts (i.e., taxable accounts) client maintains with D.A. Davidson or accounts held at other financial institutions; x Transactions clients enter into without a recommendation from D.A. Davidson or its financial professionals, or that are contrary to, or inconsistent with, their recommendation; x Ongoing recommendations of securities or other transactions or discretionary investment advice through a wrap fee program (other than Account Type Recommendations), except as otherwise agreed to in writing in such wrap fee program’s applicable agreements or disclosures; x Recommendations or investment advice that the Firm provides to clients with respect to an account that they have at the Firm, which clients choose to implement in another account or at another financial services company without the Firm’s written consent; and x Recommendations that are not fiduciary “investment advice” as defined in Department of Labor regulation section 2510.3-21 (i.e., investment advice for a fee or other compensation rendered on a regular basis pursuant to a mutual understanding that such advice will serve as a primary basis for client’s investment decision, and that will be individualized to the particular needs of client’s retirement account) The Best Interest Standard and Reasonable Compensation. The best interest standard under both the Advisers Act Fiduciary Duty and PTE 2020-02 does not require that D.A. Davidson guarantee the performance of any investment or that client’s investment objectives will be achieved. In addition, D.A. Davidson and its financial professionals may provide recommendations and take actions in connection with the accounts of other clients that may differ from the recommendations and services provided to client. There may be times when D.A. Davidson is legally prohibited from making a recommendation that may be otherwise considered to be in client’s best interest, such as due to insider trading. Client understands any recommendations D.A. Davidson, or its financial professionals make will reflect the information client provides to the Firm about their investment objectives, risk level, investment time horizon, financial information and other circumstances and D.A. Davidson will not be responsible for any information client omits or fails to provide, including changes thereto. D.A. Davidson and its financial professional’s recommendations and advice will also reflect any limitations client imposes, including through applicable investment restrictions and guidelines. Clients are responsible for notifying D.A. Davidson and their financial professionals if their investment objectives, risk tolerance and financial circumstances change. D.A. Davidson and its Financial Advisors will not be responsible for clients’ decision to invest or transfer their retirement account assets in a manner that is different from, or inconsistent with, D.A. Davidson’s recommendations or other advice and guidance, and clients assume the risk of such decision, nor will D.A. Davidson or its financial professionals be responsible for clients’ delay in implementing a recommendation. Reasonable compensation under the retirement laws has generally been determined based on the compensation paid or received in an arm’s-length transaction considering the nature and extent of all services (including products, features and benefits) provided. This standard

does not require D.A. Davidson to offer its services at the lowest cost, or for the least compensation, in the marketplace, or that it offer its services to clients at the same or lower cost or compensation levels than it offers them to other clients, including similarly situated clients. Certain clients may have negotiated lower fees and compensation for their advisory services than others. By entering into an agreement with D.A. Davidson, clients agree that they believe the fees and other compensation payable for the Firm’s services are reasonable in light of the totality of the services provided. If clients decide not to use all or some of the services made available, clients agree the Firm has no obligation or responsibility to reduce or lower its fees and compensation during the period those services are available. If clients want to change the services the Firm makes available to them or has any concerns regarding the level of fees their retirement account pays or D.A. Davidson’s compensation, client should contact their financial professional immediately. DESCRIPTION OF SERVICES Retirement Plan Services 3(21) and 3(38) Services to Plans. D.A. Davidson’s Financial Advisors with support from its Retirement Plan Services department provide services to employer sponsored retirement plans that can be held at a separate recordkeeper or Plan platform provider or, in limited circumstances, with D.A. Davidson. Retirement Plan Services are subject to the Employee Retirement Income Security Act (“ERISA”), (“ERISA covered plans” or “Plans”) and can include all or a subset of the following depending on the agreement between D.A. Davidson and the Plan sponsor or trustee (the “Plan Fiduciary”): x Assistance in preparing and monitoring investment policy statements (IPS) for compliance with ERISA requirements; x Recommend plan investments, including Qualified Default Investment Alternative (QDIA), in accordance with the Plan’s IPS, or investment mandate; x Review quarterly/annual fund management and performance versus benchmarks; x Make non-discretionary recommendations to participants on their plan investments; x Provide education to participants on their plan; x Conduct Plan expense and comparative analysis to industry averages; and x Assist with vendor search including requests for proposal (RFP). Services are typically provided pursuant to ERISA Rule 3(21) or from time to time pursuant to ERISA Rule 3(38) and are typically memorialized in a written agreement with the Plan Fiduciary. Investment recommendations made to the Plan Fiduciary are based on the investment options available with the recordkeeper or Plan platform provider and can include varying investments, such as stocks, bonds, open end mutual funds, exchange traded funds, and collective investment trusts. The Plan Fiduciary may also impose restrictions on certain types of investments or limit the number of investments available to Plan participants. As an ERISA 3(21) Investment Advisor, D.A. Davidson is a co-fiduciary to the Plan and provides non-discretionary investment recommendations to the Plan Fiduciary. The Plan Fiduciary, however, retains final decision-making authority for the investments and may accept or reject D.A. Davidson’s investment recommendations. As an ERISA 3(38) investment adviser, D.A. Davidson can provide all or a subset of these services (in addition to the services listed above): x Discretionary advice to Plans to select, remove, or replace investment alternatives available in accordance with the Plan’s IPS; x Select default investment alternatives to be used when defaulting participants; x Discretionary advice to client for risk-based model portfolios for the use of participants of the Plan's designated investment alternatives. When providing 3(38) services, D.A. Davidson has discretionary authority and is responsible for the selection, monitoring and replacement of investment options. In this case, D.A. Davidson is authorized to implement and effect investment advice without the Plan Fiduciary’s prior authorization. When an ERISA 3(38) investment adviser is appointed, the Plan Fiduciary is relieved of its fiduciary responsibility for the investment decisions but retains the duty to monitor the ERISA 3(38) activities to assure D.A. Davidson is properly performing the agreed upon tasks using the agreed upon criteria. Self-Directed Brokerage and Advisory Accounts for Plan Participants. Brokerage and advisory accounts are offered to Plan participants that wish to add a brokerage or investment advisory option for their Plan accounts (when permitted by their Plan’s rules). Such accounts are provided to Plan participants in the same manner as other brokerage or advisory accounts at D.A. Davidson, pursuant to either D.A. Davidson’s Brokerage Agreement and D.A. Davidson’s Regulation Best Interest Disclosures for brokerage accounts or D.A. Davidson’s Single Advisory Agreement and ADV Part 2A Wrap Fee Program Brochure for advisory accounts, respectively. For more information about the brokerage and advisory services provided to plan participants, see D.A. Davidson’s Regulation Best Interest Disclosures and Wrap Fee Disclosure Brochure, respectively. Financial Planning Services D.A. Davidson’s Financial Advisors who are Series 65 or 66 licensed can provide financial planning services (“Financial Planning Services”) to clients either at no additional cost to clients with an investment advisory or brokerage account or for a negotiated fee to clients or prospective clients without such accounts. Any Financial Advisors who meet specified tenure, licensing, and training requirements are permitted (at the discretion of D.A. Davidson management and the Wealth Planning Group) to charge a fee for Financial Planning Services. When clients or prospective clients engage D.A. Davidson for paid Financial Planning Services, the client enters into a written service agreement outlining the services client will receive, the duration of the engagement (typically one year), and the scope and complexity of client’s planning needs (the “Agreement”). When clients or prospective clients engage D.A. Davidson for Financial Planning Services at no additional cost, they enter into a verbal agreement to engage in the financial planning process, which terminates with the delivery of the financial plan or 90 days after the start of the financial planning relationship, whichever is earlier. A client may also request and engage in a subsequent plan review or update, which is considered a new Financial Planning Services engagement subject to a new process and timeline. D.A. Davidson offers customized Financial Planning Services designed to help clients assess their financial situation and pursue their objectives. Financial Planning Services are designed to be a collaborative experience tailored to client’s personal goals and customized to the complexity of their financial circumstances. Clients who engage D.A. Davidson for Financial Planning Services will start by engaging in a discovery interview with their Financial Advisor, where they provide certain information about their financial situation, and provide supporting documentation, which will vary based on the complexity of the plan. The Financial Advisor will review the information provided by the client and prepare an analysis that, depending on the specific needs and circumstances of the client, may integrate multiple financial planning topics. After this evaluation, clients will typically receive a financial plan, which is a goals based report that includes one or more of the following areas: Current Plan (a summary of current assets and their assignment to specific goals), Net Worth, Investment Profile, Asset Allocation Results, What If Comparison (a summary comparison of the Current Plan to an Alternative Plan), Plan Summary, Life Insurance Needs Analysis, Disability Needs Analysis, and Long Term Care Needs Analysis. The financial plan will then set forth recommendations intended to assist the client in reaching their financial goals, needs, and objectives as understood by D.A. Davidson during the particular point in time when it is prepared. Any recommendations made are general in nature and do not include any specific investments or insurance products. Financial Planning Services do not include implementation of the plan, or initial or ongoing advice regarding specific securities or other investments or insurance products. Client is not required to establish accounts, purchase products that D.A. Davidson distributes, or otherwise transact business through D.A. Davidson to implement the financial plan and D.A. Davidson does not assume any responsibility for implementing or monitoring the plan. The capacity in which D.A. Davidson is acting when helping client implement an investment strategy will depend on, and vary by, the nature of client’s account (i.e., brokerage or advisory) used for such implementation, and is not impacted by the Financial Planning Services. Please see D.A. Davidson’s Form CRS for a description of our services, D.A. Davidson’s Wrap Fee Program Brochure for details about our advisory services and Regulation Best Interest Disclosures for details about our brokerage services. Davidson Private Wealth Services D.A. Davidson’s Financial Advisors who are Series 65 or 66 licensed with members of the Wealth Planning Group (“Planning Providers”) can provide Davidson Private Wealth Services to clients with more than $20 million in stated net worth at no additional cost. When clients engage D.A. Davidson for Davidson Private Wealth Services, the client enters into a written service agreement outlining the services client will receive, the ongoing nature of the engagement, and the scope and complexity of client’s planning needs (the “Engagement Letter”). D.A. Davidson offers customized Davidson Private Wealth Services designed to help clients assess their financial situation and pursue their objectives. Davidson Private Wealth Services are designed to be a collaborative experience tailored to client’s personal goals and customized to the complexity of their financial circumstances. Clients who engage D.A. Davidson for Davidson Private Wealth Services will start by engaging in a discovery interview with their Planning Provider, where they provide certain information about their financial situation, and supporting documentation. The Planning Provider will review the information provided by the client and prepare an analysis that, depending on the specific needs and circumstances of the client, may integrate multiple financial planning topics. After this evaluation, clients will typically receive a comprehensive financial plan designed for clients receiving Davidson Private Wealth Services. The financial plan will then set forth recommendations intended to assist the client in reaching their financial goals, needs, and objectives as understood by D.A. Davidson during the particular point in time when it is prepared. Any recommendations made are general in nature and do not include any specific investments or insurance products. Estate and Tax analysis should not be considered tax or legal advice and clients are urged to consult their tax and legal professionals about the consequences of any specific strategy. Davidson Private Wealth Services do not include implementation of the financial plan, or initial or ongoing advice regarding specific securities or other investments or insurance products. Clients are not required to establish accounts at D.A. Davidson, purchase products that D.A. Davidson distributes, and otherwise transact business through D.A. Davidson or any of our affiliates in order to put into action any aspect of the financial plan. If client decides to separately engage D.A. Davidson for securities or investment products and services, the capacity in which D.A. Davidson is acting when helping client implement an investment strategy will depend on, and vary by, the nature of client’s account (i.e. brokerage or advisory) used for such implementation and is not impacted by the Davidson Private Wealth Services provided. Please see D.A. Davidson’s Form CRS for a description of our services, D.A. Davidson’s Wrap Fee Program Brochure for details about our advisory services and Regulation Best Interest Disclosures for details about our brokerage services. Davidson may also provide referrals to lawyers, CPAs, or other providers. These referrals are ancillary to the Davidson Private Wealth Services and are not a fiduciary service. The providers are minimally vetted based on certain pre-determined criteria. Davidson does not receive direct or indirect compensation as part of the referral. The Concordant Fund D.A Davidson is the manager of and adviser to Concordant Partners, LLC (“The Concordant Fund” or “The Fund”) a limited liability company organized in the state of Nebraska. The Concordant Fund is managed for D.A. Davidson by Bradley L. Knuth and Curtis K. Lane. The Concordant Fund’s investment objective is to achieve a high total return through investments in and trading of publicly traded securities, primarily, but not exclusively, shares of common stock. The Fund description and related information disclosed in this Brochure are included for informational purposes only and is not an offer to sell or a solicitation to purchase interest in or “units” of The Fund. Only sophisticated qualifying investors may invest in The Concordant Fund. Assets Under Management As of September 30, 2023, D.A. Davidson has approximately $58,000,000 in regulatory assets under management on a discretionary basis for The Concordant Fund. In addition, as of September 30, 2023, D.A. Davidson has approximately $27,925,400,000 in regulatory assets under management for its wrap fee programs. Approximately $25,259,400,000 of which was managed on a discretionary basis and $2,666,000,000 of which is managed on a non-discretionary basis. Further, information concerning D.A. Davidson’s wrap fee programs is included in the Firm’s Wrap Fee Program Brochure and is available upon request.