A. Karpas Strategies, LLC (“Karpas Strategies”) is a limited liability company (“LLC”) formed on August 11, 1999 in the State of New York. Karpas Strategies became registered as an Investment Adviser Firm in November 1999. Prior to becoming an LLC, Karpas Strategies was a sole proprietorship, of which Matthew Karpas was the sole proprietor. The sole proprietorship was registered as an Investment Adviser Firm from 1995 until 1999, when it was established as an LLC. Karpas Strategies is owned by Matthew Karpas, Karpas Strategies’ Managing Member. B. As discussed below, Karpas Strategies offers to its clients (individuals, business entities, trusts, estates, charitable organizations, etc.) investment advisory services. Karpas Strategies does not hold itself out as providing financial planning, estate planning or insurance planning services. INVESTMENT ADVISORY SERVICES The client can determine to engage Karpas Strategies to provide discretionary investment advisory services on a fee only basis. Karpas Strategies’ annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Karpas Strategies’ management (from negotiable to 1.00%) as follows: Market Value of Portfolio % of Assets First $5 million 1.00% Next $10 million 0.75% Over $15 million 0.50% for additional funds MISCELLANEOUS DISCLOSURES Limited Consulting/Implementation Services Although Karpas Strategies does not hold itself out as providing financial planning, estate planning or insurance planning services, to the extent specifically requested by the client, Karpas Strategies may provide limited consultation services to its investment management clients on investment and non-investment related matters, such as estate planning, tax planning, insurance, etc. Karpas Strategies shall not receive any separate or additional fee for any such consultation services. Neither Karpas Strategies, nor any of its representatives, serves as an attorney, accountant, or licensed insurance agent, and no portion of Karpas Strategies’ services should be construed as same. To the extent requested by a client, Karpas Strategies may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agent, etc.). The client is under no obligation to engage the services of any such recommended professional. 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. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not Karpas Strategies, shall be responsible for the quality and competency of the services provided. Please Also Note: It remains the client’s responsibility to promptly notify Karpas Strategies if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Karpas Strategies’ previous recommendations and/or services. Karpas Strategies, LLC 5 Portfolio Activity Karpas Strategies has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Karpas Strategies will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, a change in the client’s investment objective or investment performance. Based upon these factors, there may be extended periods of time when Karpas Strategies determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Karpas Strategies will be profitable or equal any specific performance level(s). Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Karpas Strategies) will be profitable or equal any specific performance level(s). Client Obligations In performing its services, Karpas Strategies 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 Karpas Strategies if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Karpas Strategies’ previous recommendations and/or services. Cash Positions Karpas Strategies continues to treat cash as an asset class. As such, unless determined to the contrary by Karpas Strategies, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Karpas Strategies’ advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Karpas Strategies may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Karpas Strategies’ advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Karpas Strategies’ Chief Compliance Officer, Matthew Karpas, remains available to address any questions that a client or prospective may have regarding the above fee billing practice Custodian Charges-Additional Fees As discussed at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Karpas Strategies generally recommends that Schwab serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab and Fidelity, generally do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Schwab will not change its transaction fee pricing in the future). Please Also Note: When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom Karpas Strategies and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA Karpas Strategies, LLC 6 member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab and/or Fidelity). These fees/charges are in addition to Karpas Strategies’ investment advisory fee at Item 5 below. Karpas Strategies does not receive any portion of these fees/charges. ANY QUESTIONS: Karpas Strategies’ Chief Compliance Officer, Matthew Karpas, remains available to address any questions that a client or prospective client may have regarding the above. Borrowing Against Assets/Risks A client who has a need to borrow money could determine to do so by using:
• Margin - The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan - In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral; These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Karpas Strategies does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). Karpas Strategies does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market).

Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Karpas Strategies:
• by taking the loan rather than liquidating assets in the client’s account, Karpas Strategies continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by Karpas Strategies, Karpas Strategies will receive an advisory fee on the invested amount; and,
• if Karpas Strategies’ advisory fee is based upon the higher margined account value (see margin disclosure at Item 5 below), Karpas Strategies will earn a correspondingly higher advisory fee. This could provide Karpas Strategies with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse Karpas Strategies, LLC 7 tax consequences). If Karpas Strategies recommends that a client roll over their retirement plan assets into an account to be managed by Karpas Strategies, such a recommendation creates a conflict of interest if Karpas Strategies will earn new (or increase its current) compensation as a result of the rollover. If Karpas Strategies provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Karpas Strategies is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Karpas Strategies, whether it is from an employer’s plan or an existing IRA. Karpas Strategies’ Chief Compliance Officer, Matthew Karpas, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Please Note: Socially Responsible Investing Limitations: Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG”). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (e.g., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Karpas Strategies), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Please Note: Use of Mutual and Exchange Traded Funds: Karpas Strategies utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Karpas Strategies’ investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Please Note - Use of DFA Mutual Funds: Karpas Strategies utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate Karpas Strategies’ services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. ANY QUESTIONS: Karpas Strategies’ Chief Compliance Officer, Matthew Karpas, remains available to address any questions that a client or prospective client may have regarding the above. Disclosure Statement A copy of Karpas Strategies’ 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. Any client who has not received a copy of Karpas Strategies’ written Brochure at least 48 hours prior to executing the Investment Advisory Agreement shall have five business days subsequent to executing the agreement to terminate Karpas Strategies’ services without penalty. Karpas Strategies, LLC 8 Assignment Neither Karpas Strategies nor the client may assign the Investment Advisory Agreement without the prior consent of the other party. Transactions that do not result in a change of actual control or management of Karpas Strategies shall not be considered an assignment. Unaffiliated Private Investment Funds Karpas Strategies also provides investment advice regarding private investment funds. Karpas Strategies, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts, and fees, including incentive compensation) is set forth in the fund’s offering documents. Karpas Strategies’ role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Karpas Strategies calculating its investment advisory fee. Karpas Strategies’ fee shall be in addition to the fund’s fees. Karpas Strategies’ clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that Karpas Strategies references private investment funds owned by the client on any supplemental account reports prepared by Karpas Strategies, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. Please Also Note: As a result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, Karpas Strategies shall calculate its fee based upon the latest value provided by the fund sponsor. C. Karpas Strategies shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, Karpas Strategies will ascertain each client’s investment objective(s). Thereafter, Karpas Strategies 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 Karpas Strategies’ services. D. Karpas Strategies does not participate in a wrap fee program. E. As of February 29, 2024, Karpas Strategies had $413,442,392 in regulatory assets under management on a discretionary basis. Karpas Strategies, LLC 9