Form ADV Part 2A, Item 4 Crestone has been in business since 2001. It is a wholly owned subsidiary of Crestone Capital LLC, whose predecessor, The Eric J. Kramer Company, was founded in 1991. The Eric J. Kramer Company (whose sole shareholder is EJK WY Trust) owns 75% or more of Crestone through its membership interest in Crestone Capital Holdings LLC, which is a Member of Crestone Capital, LLC. Crestone is a full-service wealth management firm offering investment advisory services, serving as a multi-family office for ultra-high-net-worth clients and their families. Crestone’s wealth management services include asset allocation, portfolio construction and investment selection, and comprehensive portfolio management. Crestone also serves as an outsourced chief investment officer to ultra-high-net- worth clients and their families. Crestone’s mission is to deliver extraordinary wealth-management services to select families seeking peace of mind through a trusted adviser relationship. Crestone’s investment recommendations may consist of public equities, fixed income, private equity, venture capital, real estate, and other public and private securities. Crestone also recommends and makes available investments in pooled vehicles through Crestone-sponsored private funds (which Crestone calls “Access Vehicles”) or other special-purpose vehicles. Crestone utilizes third-party investment managers to give clients exposure to specialized strategies within their portfolio. Crestone offers Family Office Client Services, Investment Advisory Client Services, Pre-Transaction Client Services, Family Foundation Services, and/or Partnership Investor Services to clients, as described below. Crestone’s Family Office Client Services encompass a robust platform of investment and wealth planning-related services including investment strategy and management; access to institutional manager search, selection, and monitoring; integrated estate, philanthropic, tax, and family governance planning; consolidated performance reporting, balance sheet aggregation, and cash flow planning. The following is a list of wealth advisory services Crestone provides, although it may provide other services depending on a client’s specific needs: Investment-Related Services Investment management advice on assets managed by Crestone
• Portfolio management
• Investment Policy Statement (“IPS”) development, portfolio strategy, and design
• Investment manager research, selection, and monitoring
• Education regarding investment philosophy, strategy, and capital markets Investment reporting
• Portfolio data and performance reports (client portal)
• Quarterly investment manager reports (client portal)
• Periodic capital account statements; income tax support and reporting
• Consolidated data aggregation and performance reporting
• Consolidated balance sheet reporting Cash Flow, Liquidity, and Credit Management
• Assistance with capital call management
• Assistance with cash flow planning and liquidity management for overall balance sheet
• Sourcing, evaluation, and ongoing management of credit facilities Wealth Planning Services In conjunction with other professionals, advise client on wealth management matters including1
• Estate planning and asset protection
• Income tax planning
• Philanthropic planning
• Family and next generation education Management of Concentrated Wealth Assets (if applicable)
• Oversee concentration risk and diversify holdings
• Advise, execute, and manage hedging strategies
• Provide reporting related to concentrated positions Other Services Sourced by Crestone but Not Provided Directly
• CPA services
• Lending options
• Legal services (estate planning/business/tax)
• Purchasing tax credits
• Corporate trustee services
• Document repository services; bill pay and bookkeeping (simple, local, virtual); tax return preparation and filing Crestone tailors its advisory services to the specific needs of its clients by determining, with each client, the types of services the client wants or needs. Crestone then creates a customized IPS based on the client’s investment preferences and objectives, spending needs, any Environmental, Social and Governance (ESG) preferences, and estate planning needs. The IPS sets investment parameters that guide Crestone

when making decisions about each client’s portfolio. Crestone does not assume full discretion over its clients’ accounts. In the IPS, each client elects to grant Crestone either limited discretion or no discretion over their accounts. In either case, the client and Crestone together will select asset classes and determine allocations within those asset classes and will agree on any other investment guidelines or limitations that the client desires to place on the accounts. Under its advisory agreements, Crestone does not have full discretion over a client’s investment decisions. Once Crestone establishes account parameters, and if the client grants limited discretion, Crestone will have the authority to direct the investment of account assets (including periodic rebalancing) and to manage the client’s account(s) within the agreed-upon investment parameters, and to determine pricing and timing of transactions, without the prior approval of the client. However, changes in asset classes, 1 Crestone does not offer tax or legal advice. Crestone will, at a client’s direction and approval, work with the client’s existing tax or legal professionals to assist in those services. Crestone may refer professionals; however, there is no compensation to Crestone for these referrals, and clients are under no obligation to use the referred services or providers. allocations within asset classes, and any other investment guidelines and limitations will be made only with the client’s prior approval. If the client does not grant discretion, Crestone will not execute any transactions in the client’s account(s) nor will it make any changes in asset classes or allocations within asset classes, such as any investment or reinvestment of account assets (including periodic portfolio management), without the client’s prior approval. Crestone’s Investment Advisory Client Services have been designed for clients who are focused on investment services only, without the all-encompassing, family office platform of services provided under Crestone’s Family Office Client Services Agreement. For such clients, Crestone will provide investment research, consulting, and advice to source and secure access to investment opportunities in Crestone’s Access Vehicles which, as more fully described below, are pooled investment vehicles such as limited partnerships and limited liability companies that invest in one or more underlying investment funds managed by unrelated investment managers, and/or direct investments, that is the opportunity to make investments directly in the underlying investment funds and/or portfolio companies themselves. The services include Crestone’s time and travel expenses related to ongoing investment manager research, due diligence, selection, and relationship management. Crestone will also provide Investment Advisory Clients with investment-sizing recommendations and ongoing investment manager oversight, including interfacing with investment managers (and/or portfolio companies, as appropriate) on behalf of clients with Access Vehicle and/or direct investments recommended by Crestone. Clients will have access to Crestone’s due diligence reports for all underlying investment managers in which a client invests. Crestone’s Pre-Transaction Client Services are for clients who expect to have a “transaction event” (such as their company plans to go public or will be acquired by another company) within the next 24 months. Pre-Transaction Client Services are designed to introduce clients to Crestone and help them plan for the transaction event. Pre-Transaction Clients receive a discounted fee for a limited time, and if or when their transaction event takes place, these clients become Family Office Clients. Crestone’s Family Foundation Services are similar to Crestone’s Family Office Client Services and have been designed for foundations that require services such as investment strategy and management, assistance with institutional manager search, selection, and monitoring, consolidated performance reporting, balance sheet aggregation, cash flow and liquidity planning, and concentrated position management, if applicable. Crestone’s Partnership Investor Services are for investors who seek access to Access Vehicles and/or direct investment opportunities sourced by Crestone. There are no additional services provided by Crestone. Crestone does not participate in wrap fee programs. As of December 31, 2023, Crestone managed approximately $ 3,406,108,668 in client assets on a limited discretionary basis and $210,152,296 on a non-discretionary basis.