Background and Ownership Structure Chilton, a Texas limited liability company, is an investment adviser that is registered with the SEC pursuant to the Advisers Act1. Chilton has been in business since January 5, 1996 and registered with SEC since February 9, 1996. Chilton became compliant with the Global Investment Performance Standards (GIPS®)2 in April of 1996. In March 2007, Chilton encompassed three entities, Chilton Capital Management LLC, Chilton Capital Management Advisors, Inc., and Chilton Capital Management Trust Company. Since December of 2012, Chilton encompasses two entities, Chilton Capital Management LLC and Chilton Capital Management Trust Company (“Chilton Trust Co.”). Chilton Trust Co. is wholly owned and controlled by Chilton. On March 8, 2018, Chilton acquired the investment advisory business of Texan Capital Management, Inc. (“Texan Capital”). Chilton and its affiliated entities are located in Houston, Texas. The primary owners of Chilton are Knapp Brothers, LLC (“Knapp Brothers”), a Texas limited liability company, and certain personnel of Chilton. Knapp Brothers have a fifty-six percent (56%) direct beneficial ownership and certain personnel of Chilton collectively have a forty-four percent (44%) beneficial ownership of Chilton. The primary two owners of Knapp Brothers are Messrs. David M. Underwood, Jr. and A. John Knapp, Jr. Chilton is managed and controlled under the direction of its Board of Managers, which is comprised of Mr. David M. Underwood, Jr., as Chairman., Mr. John E. Robertson, Ms. Laura L. Genung, Mr. Brandon Frank, and Mr. Timothy J. Lootens (collectively, the “Board of Managers”). Chilton’s senior management team is comprised of Mr. David M. Underwood, Jr., as Chief Executive Officer; Ms. Laura L. Genung, as President; Mr. Timothy J. Lootens, Managing Director and Secretary; Mr. John E. Robertson, as Officer and Managing Director; Mr. A. Chris St. Paul, as Chief Compliance Officer; Mr. Brandon J. Frank, as Chief Financial Officer; and Mr. Bradley J. Eixmann, as Chief Investment Officer (collectively, the “Senior Management Team”). Advisory Services Chilton’s investment advisory services are offered (directly or indirectly through a sub-advisory arrangement with the client's primary investment adviser) to individuals, high net worth individuals, banking or thrift institutions, registered investment companies, pooled investment vehicles, single-investor funds, discretionary and non-discretionary advisory programs, commingled investment vehicles, charitable and endowment organizations, pension and profit sharing plans (including ERISA plans), foundations, corporations, business owners, estates and trusts, other institutional type accounts (both taxable and tax- 1 Registration with the SEC does not in any way constitute an endorsement by the SEC of an investment adviser’s skill or expertise. Further, registration does not imply or guarantee that a registered investment adviser has achieved a certain level of skill, competency, sophistication, expertise or training in providing advisory services to its clients. 2 For purposes of GIPS compliance, Chilton is defined as Chilton Capital Management, which consists of two entities, Chilton Capital Management LLC, a registered investment advisor with the SEC in accordance with the Investment Advisers Act of 1940, and Chilton Capital Management Trust Company (collectively “Chilton Capital Management”). Prior to December 18, 2012 Chilton Capital Management encompassed three entities, Chilton Capital Management LLC, Chilton Capital Management Advisors, Inc., and Chilton Capital Management Trust Company. Prior to March 31, 2007 Chilton was defined as Chilton Capital Management LLC. Chilton maintains a complete list and description of composites, which is available upon request. Chilton’s effective date of compliance with the GIPS standards is April 1, 1996. exempt), government agencies, government chartered corporations, quasi-governmental agencies, state or municipal government entities and other investment advisers. Chilton currently provides portfolio management and investment advisory (or sub-advisory) services to: (i) two (2) U.S. open-end management investment companies registered under the Investment Company Act of 1940, as amended (the “Mutual Funds”); (ii) separately managed accounts (“Separate Accounts”); (iii) separately-managed account wrap programs (“Wrap Fee Programs”) offered by unaffiliated investment advisers or broker-dealers (“Sponsors”); and (iv) other proprietary accounts. The Mutual Funds, Separate Accounts and Wrap Fee Programs are each, a “Client” and collectively, the “Clients”3. The types of Clients to which Chilton provides investment management services are more fully disclosed in Chilton’s Form ADV Part 1 and summarized in Item 7 – Types of Clients of this Brochure. Chilton offers several investment strategies to Clients and in doing so may invest in a wide range of securities and other financial instruments, including: equity securities of domestic and foreign issuers (both publicly and privately traded), corporate debt securities of domestic and foreign issuers (both publicly and privately traded), master limited partnerships (“MLPs”), real estate investment trusts (“REITs”), options on exchange listed equities and indexes, private placements, warrants, registered investment company securities (including mutual funds, closed-end funds, and exchange traded funds (“ETFs”)), municipal bonds (both taxable and tax-exempt), and U.S. government securities. As financial markets and products evolve, Chilton may invest in other instruments or securities, whether currently existing or developed in the future, when consistent with the Client’s investment guidelines, objectives, and policies. Generally, Chilton invests for long‐term growth of capital and income. Within that framework, a Client’s objectives and unique circumstances may dictate that short‐term positions be taken. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss of this Brochure for more information on Chilton’s investment strategies philosophy, context and process, including portfolio construction. Chilton’s investment advisory (or sub-advisory) services consist of managing a Client’s portfolio of investments, pursuant to an investment management agreement or other similar governing agreement (the “Management Agreement”), by providing origination, acquisition, asset management, and other administrative services to each respective Client in accordance with each Client’s respective Management Agreement, prospectus and statement of additional information (e.g., registration statement), private placement memorandum, offering memorandum, offering circular, limited partnership agreement, or other similar disclosure and governing documents (collectively, the “governing documents”). Chilton’s investment advisory services consist of, but are not limited to, managing each Client’s portfolio of investments, including sourcing, selecting, and determining investments in each Client’s portfolio, monitoring investments by each Client and executing transactions on behalf of each Client, including investing and re-investing the assets of each Client’s portfolio in accordance with the investment objectives, policies and guidelines set forth in each respective Client’s governing documents. Accordingly, Chilton’s investment advisory services to the Mutual Funds are not tailored to the individualized needs or objectives of any particular Mutual Fund shareholder. An investment in a Mutual Fund by a shareholder does not, in 3 As an SEC-registered investment adviser, Chilton owes a fiduciary duty to all of its Clients. An investment in a fund by an investor or shareholder does not, in and of itself, create an advisory relationship between the investor or shareholder and Chilton. Investors or shareholders are not permitted to impose restrictions or limitations on the management of any fund. In 2006, the decision by the Court of Appeals for the D.C. Circuit in Goldstein v. SEC, 451 F.3d 873 (D.C. Cir. June 23, 2006), with respect to funds, clarified that the “client” of an investment adviser to a fund is the fund itself and not an investor in the fund. and of itself, create an advisory relationship between the shareholder and Chilton. Shareholders are not permitted to impose restrictions or limitations on the management of the Mutual Funds. Except for certain Wrap Fee Programs discussed below, when Chilton serves as investment adviser, it enters into a written Management Agreement with each of its advisory Clients, as described herein above. Such Management Agreements include provisions related to each Client’s management fees, investment

strategy, investment guidelines, termination rights, proxy voting and sub-adviser, if applicable. Chilton’s standard Management Agreement contract generally permits either party to terminate the contract at the end of any calendar quarter following thirty (30) days’ written notice or at any time following sixty (60) days written notice for the Mutual Funds and other pooled investment vehicles. Upon termination, Clients are billed only for the pro-rata portion of the management period. Clients do not pay a termination fee. When Chilton serves as a sub-adviser, Chilton enters into a sub-advisory agreement with an unaffiliated investment adviser. These sub-advisory agreements typically include information related to Chilton’s sub- advisory fee, investment strategy, investment guidelines, termination rights and proxy voting. The unaffiliated investment adviser enters into an investment management agreement with the end client. Tailored Advice and Client-Imposed Restrictions As stated herein above, Chilton’s investment advisory (or sub-advisory) services consist of managing a Client’s portfolio of investments, pursuant to the agreed upon terms of a Management Agreement. Each Management Agreement is separately negotiated and designed to suit the needs of each particular Client and their respective investment objectives, policies, and guidelines as set forth in each respective Client’s governing documents. Accordingly, Chilton tailors its investment advisory services to the individual needs of each respective Client and is subject to applicable investment objectives, policies, and guidelines set forth in the governing documents for each respective Client. Such Management Agreements may impose restrictions on Chilton’s ability to invest in certain securities or types of securities. Additional portfolio restrictions may also include exposure limits, concentration limits, industry and sector limits, geographical limits, and liquidity limits. Chilton works with Clients to formulate appropriate and agreed-upon investment guidelines. Additionally, Chilton works with Clients to determine the feasibility of monitoring proposed restrictions and limitations. Clients who restrict their investment portfolios may experience potentially worse performance results than Clients with unrestricted portfolios even for Clients with similar objectives. Chilton reserves the right to reject or terminate any Client that seeks restrictions which Chilton is unable to implement or which may fundamentally alter the investment objective of the strategy selected by the Client. Investors who participate in pooled investment vehicles, such as the Mutual Funds, generally may not tailor investment guidelines. Prospective clients and prospective client investors must consider whether a particular Chilton advisory relationship is appropriate for their own circumstances based on all relevant factors including, but not limited to, the prospective client’s own investment objectives, liquidity requirements, tax situation, and risk tolerance. Prospective clients are strongly encouraged to undertake appropriate due diligence including, but not limited to, a review of governing documents relating to the proposed investment program for the prospective client and to investigate additional details about Chilton’s investment strategies, methods of analysis, and related risks, before making an investment decision or committing to a service provided by Chilton. See Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss of this Brochure for a more detailed discussion on investment strategies and the risks involved with such strategies. Wrap Fee Programs Chilton offers certain of its investment strategies to Clients invested in three different types of Wrap Fee Programs:
• “Single Contract Programs” in which Chilton enters into a contract with a Sponsor to provide discretionary advisory services to the Sponsor’s Clients;
• “Dual Contract Programs” where Chilton enters into a contract directly with the Client to provide discretionary advisory services and the Client enters into a separate contract with the Sponsor, custodian and other service providers In Single and Dual Contract Programs, Sponsors introduce Clients to Chilton and generally provide Clients a package of services which may include any or all of the following: discretionary investment management, trade execution, account custody, performance monitoring and manager evaluation. Sponsors receive a (“Wrap Fee”) from Clients for providing this package of services and Chilton receives a portion of the Wrap Fee from the Sponsor for its investment management services. Sponsors typically: (i) assist Clients in defining their investment objectives based on information provided by the Clients; (ii) determine whether the given Wrap Fee arrangement is suitable for each Client; (iii) aid in the selection and monitoring of investment advisers (whether Chilton or another adviser) to manage accounts (or a portion of account assets); and (iv) periodically contact Clients to ascertain whether there have been any changes in Clients’ financial circumstances or objectives that warrant changes in the arrangement or the manner in which Clients’ assets are managed. Chilton generally receives Client information through Sponsors and relies on Sponsors to forward current and accurate Client information on a timely basis to assist in Chilton’s day-to-day management of Clients’ accounts. Single and Dual Contract Program Clients may also contact Chilton directly concerning their accounts. Under the typical Model Program, Chilton provides Sponsors or overlay managers with initial model portfolios at the inception of the arrangement and then provides updates of the model portfolio on a regular basis as part of Chilton’s trade rotation procedures or at such other intervals agreed to by Chilton and the Sponsor. See Item 12 – Brokerage Practices for more information on trade rotation. Investors in Model Programs do not have direct access to Chilton. In these programs, Sponsors or overlay managers have investment discretion to accept, reject or modify Chilton’s trade recommendations and apply them to their Clients’ accounts. As a result, Chilton generally does not consider these assets as discretionary assets. In certain cases, Chilton may enter Model Programs and retain investment discretion; however, Chilton may not have the responsibility to place orders for the execution of trades for Clients. In these instances the Sponsors (or the broker-dealer affiliated with the Sponsors) are solely responsible to execute transactions for such trades and are solely responsible for providing best execution for such trades. Clients investing in Wrap Fee Programs generally may invest in Chilton strategies with lower account minimums than other account types; however, Wrap Fee Programs may not be suitable for any given Client. Suitability depends on a number of factors, including the applicable Wrap Fee, account size, anticipated account trading activity, the Client’s financial needs, circumstances and objectives, and the value of the various services provided. Clients should consult with their Sponsor to determine whether investing through a Wrap Fee Program is suitable for their circumstances. Chilton’s suitability responsibility is limited to ensuring that investments chosen for an account are appropriate in light of the investment strategy selected by a Client or the Sponsor. Smaller Wrap Fee Program accounts may not receive or be able to fully implement all of Chilton’s investment recommendations for a particular strategy depending on the price of securities and the size of the account. Chilton may also be restricted from investing in certain securities due to operational constraints or limitations set by the Sponsor. Clients investing in Wrap Fee Programs should receive a brochure from the Sponsor detailing all aspects of the Wrap Fee Program prior to selecting Chilton as an investment manager. Clients should review program documentation carefully and discuss with their financial adviser whether these programs, and Chilton’s strategies, are appropriate for their investment needs and circumstances. Regulatory Assets Under Management As of December 31, 2023, Chilton managed approximately $2,205,361,164 of advisory assets, of which all were on a discretionary basis and none were on a non-discretionary basis. The SEC has adopted a uniform method for advisers to calculate assets under management for regulatory purposes which it refers to as an adviser’s “regulatory assets under management.” Regulatory assets under management are generally an adviser’s gross assets, i.e., assets under management without deduction for outstanding indebtedness or other accrued but unpaid liabilities. Chilton reports its regulatory assets under management in Item 5 of Part 1 of Form ADV which you can find at www.adviserinfo.sec.gov.