A. Colorado Financial Management LLC is a Delaware limited liability company that is the successor entity to Sargent Bickham Lagudis LLC, d/b/a Colorado Financial Management, which was a Colorado limited liability company formed in December 1998 (predecessor and successor entities shall be referred to as “Firm” or “CFM”). The Firm became registered as an investment adviser with the Securities and Exchange Commission (“SEC”) in March 1999. B. On February 27, 2023, Sargent Bickham Lagudis LLC d/b/a Colorado Financial Management entered into a transaction with Lido Advisors, LLC (“Lido”), a Los Angeles-based investment adviser registered with the Securities and Exchange Commission, whereby, among other things, Sargent Bickham Lagudis LLC (“SBL”) was acquired in full by Lido (the “Transaction”). Subsequently SBL changed its name changed to “Colorado Financial Management, LLC” (“CFM”) and will operating as Colorado Financial Management, A Lido Company. Further, CFM’s clients assigned their investment advisory agreements to Lido, and CFM became the sub-advisor to manage these clients. All of CFM’s personnel, offices, and operations remain in place. C. As discussed below, the Firm offers to its clients (individuals, business entities, pension and profit-sharing plans, trusts, banks or thrift institutions, estates and charitable organizations, etc.) investment advisory services and financial planning and related consulting services when applicable. Investment Advisory Services The client can determine to engage the Firm to provide discretionary and/or non-discretionary investment advisory services on a fee-only basis. In addition, CFM acts as a sub-advisor to certain Lido clients, formerly CFM clients, at a fee determined by Lido, and provides these services to these clients, under Lido’s supervision., The Firm's annual investment advisory fee is set out in the Investment Advisory Agreement and includes investment advisory services, and may include, to the extent specifically requested by the client and agreed to by the Firm, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of the Firm), the Firm may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice agreed to by the client. Before the Firm provides investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, the Firm will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, the Firm provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent requested by the client, the Firm may determine to provide extraordinary financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone, separate fee basis. The Firm’s planning and consulting fees may either be a fixed fee or on an hourly basis and are negotiable depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging the Firm to provide planning or consulting services only, clients are generally required to execute an agreement with the Firm setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to the Firm commencing services. If requested by the client, the Firm may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Firm. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note:

It remains the client’s responsibility to promptly notify the Firm if there is ever any change in his/her/its financial situation, tax status, or investment objectives for the purpose of reviewing/evaluating/revising the Firm’s previous recommendations and/or services. Miscellaneous Non-Investment Consulting/Implementation Services. To the extent requested by the client, the Firm may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Neither the Firm, nor any of its representatives, serves as an attorney, accountant, or licensed insurance agent, and no portion of the Firm’s services should be construed as same. To the extent requested by a client, the Firm may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Firm. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Firm if there is ever any change in his/her/its financial situation, tax status, or investment objectives for the purpose of reviewing/evaluating/revising the Firm’s previous recommendations and/or services. Client Obligations. In performing its services, the Firm shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify the Firm if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising the Firm’s previous recommendations and/or services. Disclosure Statement. A copy of the Firm’s written Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or financial planning agreement. C. The Firm shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Firm shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Firm’s services. D. The Firm does not participate in a wrap fee program. E. As of December 31, 2022, the Firm had $1,939,791,435 in assets under management on a discretionary basis and $12,126,814 in assets under management on a non-discretionary basis. Fiduciary Responsibility for Retirement Accounts When we provide investment advice to a client regarding a retirement plan account or individual retirement account, CFM is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way CFM makes money creates some conflicts with your interests, so we operate under a special rule that requires us to act in the best interest of the client and not put CFM’s interest ahead of the client’s interest. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice)
• Never put CFM’s financial interests ahead of the client’s financial interests when making recommendations (give loyal advice)
• Avoid misleading statements about conflicts of interests, fees, and investments
• Follow policies and procedures designed to ensure that CFM gives advice that is in the best interest of the client
• Charge no more than is reasonable for services provided
• Give the client basic information about conflicts of interest