Firm Description Our firm was founded in 1937 and has been registered under various names since the original inception. In 2001, the firm transitioned to OSBORNE PARTNERS CAPITAL MANAGEMENT, LLC (“OPCM”). The firm has two chief offices, one located in San Francisco and one located in Menlo Park. In 2021, a branch office was opened in West Linn, Oregon. The San Francisco office is the main headquarters. San Francisco Office Silicon Valley Office One Embarcadero Center, Ste. 4100 545 Middlefield Road, Ste. 165 San Francisco, CA 94111 Menlo Park, CA 94025 Phone: (415) 362-5637/(800) 362-7734 Phone: (650) 854-5100/(800) 397-5101 Fax: (415) 362-5996 Fax: (650) 854-5661 Oregon Office West Linn, OR 97068 Phone: (503) 757-4584 Fax: (650) 223-6268 The firm is a Registered Investment Adviser (“RIA”) with the Securities and Exchange Commission (“SEC”). However, being registered with the SEC is not meant to imply a specific level of training or skill and is not meant to denote any form of recommendation or endorsement by the SEC of state securities regulators. We encourage the reader to carefully read this document to examine OPCM and our practices, and to discuss any potential business relationship with your own knowledgeable business advisers and legal counsel. Principal Owners The majority ownership of the firm is held by employees of the firm. The allocations for employees and owners of more than 5% are as follows: Daniel M. Haut: less than 5% Jay M. Skaalen: less than 5% Alicia W. Cheng: less than 5% Sonia J. Von Berg: less than 5% Charles J. Else: less than 5% Focus Financial Partners, LLC*: 10% but less than 25% Justin W. McNichols: 25% but less than 50% OPCM Holdings, LLC**: 25% but less than 50% * Focus Financial Partners Inc. is the entity that owns the interest above. ** Norman D. Villarina is a Managing Partner of Industry Capital Partners II, LLC., which is the entity that owns the interest listed above. Tailored Relationships OPCM provides personalized investment management to individuals, families, trusts, estates, conservatorships, foundations, endowments, corporations or business entities and pension and profit-sharing plans, charitable organizations, public funds, investment limited partnerships, 401(k) plans, 401(k) self-directed accounts, IRAs and other retirement plans, through direct advisory relationships and via a sub-advisory arrangement. All portfolios are actively managed by our investment team and are tailored and managed according to an individually prepared client Investment Policy Guidelines, which reflects the specific financial objectives, taxability, and risk tolerance of the client. OPCM does not assume any responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.). Under all circumstances, clients are responsible for promptly notifying OPCM in writing of any material changes to the client’s financial and investment objectives, taxability, time horizon, or risk tolerance. Client Imposed Restrictions Clients can impose restrictions on investing in certain securities, types of securities or asset classes, in accordance with their values, beliefs or employer requirements. When imposing a restriction, we require restrictions be given at the start of the relationship, be focused, naming specific securities and detailed in writing and approved by OPCM and the client. Our view is that certain types of restrictions requested by a client can be vague, broad in nature, and be very subjective. One such example of a vague restriction is “no sin stocks”. Due to the vague nature of what a “sin stock” is, the firm cannot enforce such restrictions. The restriction must detail the specific securities that OPCM would be prohibited from purchasing. It is OPCM’s policy to not purchase any tobacco related stocks. Clients who request a tobacco restriction will have their account(s) restricted but will not be prohibited from inclusion in the composite performance. Our first priority is to purchase securities in client accounts that we believe will provide the best overall growth for the client to reach their investment objectives and goals, while taking into consideration the client’s tolerance for risk. Types of Advisory Services Investment Management Services OPCM offers investment management services directly to clients on a discretionary and non-discretionary basis. We tailor and manage each portfolio according to individually prepared Investment Policy Guidelines, which reflects the specific financial objectives, taxability, and risk tolerance of the client. The six types of investment strategies OPCM offers are as follows: Global Equity Strategy, Global Growth Strategy, Global Moderate Growth Strategy, Global Balanced Strategy, Global Income Strategy, and the Fixed Income Strategy. Our Global Growth, Global Moderate Growth, Global Balanced, and Global Income strategies are allocated over two or more of the following asset classes: equities (domestic and foreign), fixed income, natural resources, real estate, and alternative asset classes. Strategies are comprised of publicly traded securities. For our Global Equity Strategy, we use a bottom-up fundamental discipline with a quantitative overlay to provide a value approach to growth investing. We use deep fundamental research to focus on a company’s earnings quality and growth, balance sheet quality and trends, and absolute and relative valuation. For our Fixed Income Strategy, our discipline typically revolves around high quality issues with the highest yield for the lowest maturity and duration. Portfolios can include fixed income funds and fixed income ETFs. OPCM also provides investment management services to 401k plans, wherein OPCM provides management for three types of plan account offerings. The plan account types include:  Traditional – managing a menu of Exchange Traded Funds that can be chosen for investment by plan participants  Model portfolios – managing certain asset allocation portfolios, which can be selected by a plan participant  Self-directed – managing plan participant accounts based on individual investment objectives utilizing various asset classes. Sub-Advisory Arrangement OPCM is engaged as a sub-adviser by an unaffiliated investment adviser. As a sub-adviser, OPCM does not enter into a contract with clients. The agreement is entered between OPCM and the unaffiliated investment adviser to hire OPCM to provide investment management services to certain clients of the investment adviser that are delegated to OPCM (“Sub-Advisory Client”). In a sub-advisory relationship, each Sub-Advisory Client enters into an investment advisory agreement with the unaffiliated investment adviser. The agreement gives the unaffiliated investment adviser the authority to hire, monitor, and fire sub-advisers on behalf of a Sub-Advisory Client. The Sub-Advisory Client is not a direct client of OPCM and remains solely the client of the unaffiliated adviser. OPCM, in its capacity as a sub-adviser, delivers its investment management services through its arrangement with the unaffiliated investment adviser. Under the sub-advisory agreement, OPCM is granted discretionary authority to invest a Sub-Advisory Client’s assets based on the investment strategy selected by the unaffiliated investment adviser. The unaffiliated investment adviser is responsible for determining if the Sub-Advisory Client is suitable for receiving OPCM services. Wrap Programs We currently do not participate in any Wrap Fee Programs. A Wrap Fee Program is an arrangement

between a broker-dealer and other financial institutions, who act as the sponsor of an investment program through which their clients can receive discretionary investment advisory services. The wrap program sponsor provides the investment platform, execution services, clearing, and custodial services in a “bundled” form, meaning the client is charged one fee for all services. The fee charged is usually based on a percentage of the assets held in the account. When OPCM decides to participate in a wrap program, we will manage the accounts in the same manner as our advisory clients with the investment and financial objectives provided by the broker-dealer. Affiliated Private Hedge Fund Finally, the firm manages an Absolute Return Strategy, which is only provided through the OPCM Absolute Return, L.P., an affiliated private hedge fund (“OPCM Fund”). The OPCM Fund is only open to individuals who meet the accredited investor and qualified client standards. The OPCM Fund invests in and trades securities, consisting principally, but not solely, of equity and equity related securities that are traded publicly in U.S. markets. The OPCM Fund can invest in other types of securities and engages in short selling and hedging, margin trading, and other investment strategies. Prospective investors are provided with an offering circular and other documentation that detail the investment objectives, risks, fees, and other important information about the OPCM Fund. It is important that each potential investor fully read all the offering documents prior to investing. Investing in the OPCM Fund is only available to persons who are deemed “accredited investors” under the Securities Act of 1940, as amended and “qualified client” as defined in Rule 205(3) of the Investment Advisers Act of 1940. The OPCM Fund is not made available to the public and is not a registered investment company. The OPCM Fund can be offered to current clients meeting the required qualifications, in conjunction with the overall asset allocation and management of the client’s account. OPCM’s disclosure of information within this Brochure that pertains to the OPCM Fund is not intended to be a solicitation for or an advertisement of the fund. Instead, such disclosures have been made to provide important information about the services provided by OPCM and the overall risks involved in these types of activities as they relate to OPCM’s advisory business. OPCM has in the past, but no longer recommends that a portion of such client’s assets be invested in certain non-affiliated private pooled investment vehicles (e.g., private funds, limited partnerships). These included private hedge funds that invest in alternative type investments, real estate funds, oil and gas partnerships, and other types of private investment vehicles (collectively “Private Funds”). Prior to investing, clients were provided with private placement memorandums and other offering and subscription documentation that detail the nature, risks, and associated fees of each Private Fund. OPCM’s strategies are based on long-term investing, and we are dedicated to achieving our clients’ goals and objectives. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for further details on the above-mentioned investment strategies and services. Assets Under Management OPCM manages approximately $2,169,812,155 in assets for approximately 699 client relationships as of December 31, 2023. The assets are broken down as follows: OPCM manages $2,124,124,147 on a discretionary basis. OPCM manages $45,688,008 on a non-discretionary basis. Discretionary assets under management include the assets managed in the OPCM Fund and sub-advisory clients. Types of Agreements OPCM provides investment advisory services on a discretionary basis for the majority of our clients; however, we do provide non-discretionary asset management services under certain circumstances. OPCM’s advisory agreement gives us the authority to buy and sell securities for our designated client accounts. In addition to our agreement, the custodian requires a limited power of attorney signed by the client to allow us to transact within our client accounts. Termination of Agreement A client or unaffiliated investment adviser in which OPCM has a sub-advisory agreement with can terminate any of the aforementioned agreements at any time by notifying us 30 days in advance, either in writing or electronically via email. The termination notice will not affect commitments actually made prior to receiving the termination notice. At termination, fees will be billed on a pro rata basis for the portion of the quarter completed. The portfolio value as of the termination date will be used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination. For clients billed in arrears, we will issue a closing fee bill based on the number of days you received investment management services in the current quarter. If we are authorized to debit the fee directly from your account at the time of termination, we will debit the fee from your account for the balance due. If we are not able to debit your account directly or if you have not authorized us to debit the account directly, we will issue you a closing bill for payment. You are responsible for paying any balance due to OPCM. In either instance, we will provide you a copy of the closing fee bill for your records. For clients billed in advance, we will issue you a refund based on the number of days you received investment management services in the current quarter. We will either credit your account directly for the refund or issue your account a refund in the form of a check to your address of record. OPCM can terminate any of the agreements at any time by notifying you in writing. In addition, OPCM reserves the right to terminate any investment advisory services when a client fails to provide pertinent information about their account or financial situation when it is necessary and appropriate, and in our judgment, when the lack of information impairs us from properly providing prudent investment and or financial advice. 401k Participant Accounts When we manage a client’s 401K participant account, if such account is held at a custodian that is not directly accessible by OPCM (“Held Away Account”), we will request permission from such client to use a platform that is administered by a third-party service provider. The platform gives OPCM the ability to view the 401K account assets in real time and effectively place transactions. OPCM has entered into a subscription agreement with the third-party service provider and when a client agrees to OPCM’s use of the platform, the service provider’s terms and conditions agreement for users will be made available within the platform. It is important for clients to review the agreement in its entirety in order to be fully aware of all conditions and requirements. For example, the terms and conditions include, but are not limited to, the client agreeing to provide the third-party service provider with access to all account information in their 401K account and authorizing OPCM to use the platform to facilitate the investment management of your 401K account. OPCM will be granted access to view and manage the client’s 401K account assets via a platform login. The login access does not give OPCM the authority or ability to transfer or withdraw any assets in a client’s 401K account. OPCM is not affiliated with the third-party service provider, and we do not receive any compensation from them for using their platform. There is a fee charged by the third-party service provider for the use of the platform, which is paid by OPCM, not our clients.