A. Description of Advisory Firm Symmetry® Partners, LLC (“Symmetry”) is an investment adviser registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940 (the “Advisers Act”). The firm is located in Glastonbury, Connecticut and was established in 1994. The firm was founded by and is currently owned and operated under the control of David E. Connelly, Jr. and Patrick A. Sweeny. As of December 31, 2023, Symmetry had approximately $7.9 billion in assets under management and advisement. Assets under advisement are those for which Symmetry acts as a sub-advisor. B. Types of Advisory Services Symmetry Partners’ methods of analysis and investment strategies are based on academic research into optimal investing, with an emphasis on Modern Portfolio Theory (MPT) and Quantitative Methods of Analysis that extend from MPT. Symmetry’s analysis methods may include: use of MPT metrics such as return, standard deviation, and Sharpe Ratio, etc. Please see definitions of these terms in item 8 of the brochure. Symmetry’s investment strategies consist of equity, fixed income, and alternative components (or one or the other) and are comprised of open-end mutual funds, exchange traded funds, and sub-advised accounts. Symmetry currently creates portfolios utilizing open-end mutual funds and exchange traded funds. These portfolios are called Symmetry Panoramic Portfolios, PrecisionCore ETF Portfolios and PrecisionCore Factor ETF Components, Symmetry Bond Portfolios, AltAxis Portfolio, Symmetry ESG, Symmetry Socially Responsible, and Symmetry Axiom Sector Momentum. As part of the Symmetry Retirement program, Symmetry offers the Structured Portfolios, a target date version of the Structured Portfolios called the Evolution Portfolios. Symmetry also creates customized individual security portfolio solutions under the Axiom program, designed to give clients exposures similar to several diversified indices, as well as offering specific factor emphasis. In addition, Symmetry may collaborate with unaffiliated Registered Investment Advisors (“RIA”), to create a customized suite of portfolios for mutual clients. Symmetry selects funds suitable and consistent with the firm’s investment philosophy. Symmetry is not obligated to use any specific security in the creation of the portfolios, as Symmetry is not affiliated with the sponsor or adviser of any fund or security, except for the Symmetry Panoramic Models (previously known as Structured Panoramic). Symmetry does not exclusively recommend portfolios. As part of the Symmetry Retirement program, Symmetry will recommend a menu of individual mutual funds, known as IndexElect, to plan sponsors who wish to have a selection of individual funds for the plan’s participants. Through the Symmetry Retirement program, Symmetry manages assets for qualified plans such as, but not limited to, 401(k), money purchase, profit sharing, defined benefit plans and institutional pension plans. As a part of the Axiom program, Symmetry may provide consultative advice on combinations of Symmetry portfolio offerings for advisors to consider for a mutual client. Periodically, vetted ETFs or mutual funds may be included in Axiom recommendation outside of a portfolio sleeve. Symmetry provides advisory services acting as a strategist/sub-advisor/model manager to/on various technology, broker-dealer, custodian, and RIA management platforms. Symmetry offers these portfolios, programs and investment advisory services to clients who are referred to Symmetry’s services through investment adviser and registered representatives of unaffiliated independent Broker-Dealers and Registered Investment Advisers, (labeled “BD/RIA” or “BD/RIAs’’ for this document’s purpose). Symmetry also provides these services to a limited number of legacy clients obtained directly through its own investment adviser representatives (“IARs”). Legacy Clients obtained through Symmetry’s IARs efforts may access financial planning as part of the services provided by Symmetry. Symmetry also provides investment advice and due diligence services through its OCIO (Outsourced Chief Investment Officer) program. OCIO services are contracted on a case- by-case basis. In most cases, the unaffiliated RIA will pay for these services directly from the revenue generated from their existing service. In some cases, OCIO relationships may contract to invest in Symmetry offerings that will incur a basis point charge to the client. Symmetry also provides investment advisory services to the Symmetry Panoramic Funds (each a Fund and collectively the “Funds”) which are registered with the SEC under the 1940 Act, (“40 Act’) and the Securities Act of 1933. Symmetry Panoramic Mutual Funds Symmetry provides investment advisory services to the Symmetry Panoramic Funds. The Funds are a series of the Symmetry Panoramic Trust, a Delaware statutory trust (the “Trust). The Trust is registered as open–end management investment company under the 40 Act, as amended. The presentation of information in this brochure relating to the Symmetry Panoramic Funds is not intended as an offer or solicitation to invest. Additional information about the Symmetry Panoramic Funds is available in the Funds’ prospectus and Statement of Additional Information, (“SAI”), which are available on the Funds’ website, (www.panoramicfunds.com), or on the SEC’s EDGAR database. Symmetry Panoramic Models The Symmetry Panoramic Funds will be used as holdings in the Symmetry Panoramic and Panoramic + Alts Models. The Panoramic Models will be comprised entirely of Symmetry Panoramic Funds. Different Panoramic Models may hold different Panoramic Funds at different weights. Symmetry will maintain other versions of the Structured models that invest directly in Underlying Funds, in instances where adopting the Panoramic Fund version is impracticable or undesirable. It should be noted that the Symmetry Panoramic Models will not be immediately available through all distribution channels. A model comprised of the Symmetry Panoramic Funds will be labeled Symmetry Panoramic Models. Symmetry PrecisionFactor ETF Portfolios The Symmetry PrecisionCore ETF Portfolios are a suite of asset allocation model portfolios comprised exclusively of ETFs, from unaffiliated fund providers. The PrecisionCore ETF portfolios, tax-managed and non- tax-managed, are comprised of an equity and fixed income allocation and vary both in their allocation between equity and fixed income and the relative risk profile of the fixed income positions. As the risk rating of the models increases, the fixed income assumes a higher risk posture. The equity portion of each PrecisionCore ETF Portfolio provides exposure across global equity asset classes to provide a high level of diversification. Symmetry periodically updates the model allocation to keep it in line with the current relative capitalization of US, international, developed and emerging markets. Clients are rebalanced periodically to maintain their desired equity to fixed income allocation and put all positions back to or near the current target for their model portfolio. Symmetry also offers component models including US PrecisionEquity, International PrecisionEquity, PrecisionCore Bond, and PrecisionCore Tax-Managed Bond, which allow advisors to combine different geographic exposures to their clients specific needs. Symmetry Bond The Symmetry Bond Portfolios are two standalone fixed income asset allocation portfolios, one tax- managed, one non-tax-managed. The Symmetry Bond Portfolios are currently comprised of open-end mutual funds from DFA and Vanguard. Each of the Symmetry Bond Portfolios are designed as a standalone fixed income product that takes some fixed income risks. The tax-managed version of the Symmetry Bond Portfolio features an allocation to national, short-term, high-quality municipal bonds in addition to other holdings. The non-tax- managed version holds a short-term bond fund in addition to other holdings. Each of the two versions of Symmetry Bond Portfolios include an allocation to Treasury Inflation-Protected Securities (TIPS), in order to provide partial protection of purchasing power. Symmetry AltAxis The AltAxis Portfolio is a portfolio of several mutual funds, currently comprised of funds from AQR Capital Management (“AQR”), designed to diversify traditional equity and fixed income holdings. The portfolio's underlying funds attempt to access a wide array of alternative premiums captured by long- short investment strategies across multiple asset classes. The portfolio is not designed to be 100% of a client's investable assets, in aggregate. Typical investors in this portfolio are seeking a strategy that diversifies traditional equity and fixed income portfolios. Alternative strategies have unique risks that may not be reflected in standard deviation alone. In addition, the funds in this model may make extensive use of derivatives in order to achieve very specific exposures and apply leverage to the strategy. Symmetry ESG The Environmental, Social and Governance (ESG) Portfolios are designed for clients looking to align their investment portfolios with their values, are seeking a low-cost, tax efficient portfolio, and are seeking a balanced strategy that can be aligned with a client’s risk objectives. The ESG portfolios provide a combination of exclusionary screens and best-in- class optimizations that together achieve a greater focus on industries and companies deemed more consistent with ESG goals. Generally speaking:
• Environmental considers how companies perform as a steward of nature.
• Social criteria looks at how companies manage relationships with employees, suppliers, customers, and the communities where they operate.
• Governance considers companies’ leadership, executive pay, audits, internal controls, and shareholder rights. Symmetry Socially Responsible The Symmetry Socially Responsible Portfolios also seek to allow clients to align their investment portfolios with their values, are seeking a low-cost, tax efficient portfolio, and are seeking a balanced strategy that can be aligned with a client’s risk objectives. This suite of portfolios seeks to reduce exposure to companies that do not align with certain social screens such as production of nuclear weapons, land mines, tobacco, alcohol, cannabis, and contraceptives, as well as revenue generation from gambling and pornography. Axiom Symmetry’s Axiom services includes two distinct separately managed account (SMA) options. The Investable Index Series targets popular equity indexes, while the Factor Strategies are designed to capture strategies comprised of individual stocks and ADRs. Your Financial Advisor may utilize either of these Models to serve several construction objectives inside your portfolios. Your Financial Advisor may wish to use these Models as a core module inside of a larger core/satellite portfolio. These Models may also be suitable as a starting point to express your preferences for sector or security level customizations that could otherwise not be expressed through a pooled vehicle such as an ETF or Mutual Fund. Finally, these Models may be utilized as a tax-aware module within your portfolio where specific tax lots of individual securities may be loss- harvested (see Tax Overlay Management Services) while at the same time demonstrating index- like tracking characteristics. While the Models themselves are not managed in a tax sensitive fashion, the structure does help facilitate more effective tax management from the dispersion among a sample of the constituent securities of an index as well as the potential for various tax lots for these securities.
• Investable Index Series Our Investable Index Series was designed to provide your Financial Advisor with Model options that behave in a manner similar to a broad-market index while, at the same time, allowing for customization and active overlay management techniques through individual security ownership.
• Factor Strategies Our Factor Strategies are comprised of diversified investment solutions that include individual stocks and ADRs. These portfolios are constructed based on quantitative rules-based methods that seek to capture specific factor premiums, such as Value, Momentum and Profitability, and will rebalance on a regular basis to maintain intended diversification and factor exposures. Portfolios of individual securities may be the appropriate solution for clients with tastes and preferences or needs that are better met by these portfolios. The current multi-factor offering includes strategies that cover the United States, International, and Global geographies and can include factors such as Value, Momentum, and Profitability (or Quality). Individual factor strategies are available in the United States market targeting individual factor strategies such as Value, Momentum, Yield, and Defensive.
• Axiom Sector Momentum The Axiom Sector Momentum Portfolio is constructed from ETFs and seeks to provide exposure to the sectors of the S&P 500 that most recently performed well based on 6 and 12 month momentum signals.
• Custom Model Strategy The BD/RIA’s investment adviser or registered representatives may also suggest a Custom Model Strategy portfolio to the clients. A custom allocation combines various Symmetry portfolios, to create a new portfolio. Symmetry representatives may provide consultation regarding how to combine its strategies. The combining of the portfolios will create a new asset allocation, using all the funds that were in the underlying portfolios used to create the new portfolio. There are no funds added or removed from the target allocation in the custom portfolio. Please note the Symmetry Evolution Portfolios cannot be used in the Custom Model Strategy program. The Custom Model Strategy may not be available at all custodians. Please note with Axiom there are minimum investment levels.
• Tax Overlay Management Services If selected by your Financial Advisor, Symmetry can provide Tax Overlay Management services to your AXIOM account. In providing Tax Overlay Management services, we consider the tax consequences of transactions in your account and will adjust our AXIOM services accordingly. We attempt to accomplish tax-aware investment management through gain-loss matching, harvesting losses and/ or gains, deferring gains until securities reach preferential tax status, and avoiding imprudent wash sale transactions to improve the after-tax return while staying as

consistent as possible with the risk/return characteristics of your account’s Strategy. Our ability to improve your after-tax return depends on various factors beyond our control including economic and market conditions, regulatory changes, actions taken by your custodian broker-dealer, the specifics of your account’s strategy, the starting portfolio in your account, your tax circumstances and mandates as communicated by your Financial Advisor. Tax Overlay Management may cause the actual performance in your account to vary from the "stated" performance of the Strategy’s Manager. Tax Overlay Management services are provided solely in connection AXIOM services provided to your account. We do not provide general tax planning advice or services. To provide Tax Overlay Management services, we rely solely on the information provided by your Financial Advisor and your custodian broker-dealer. If that information is inaccurate, incomplete or not timely, our ability to provide Tax Overlay Management may be adversely affected. We make no guaranty that taxes in your account will be reduced. If an account contains mutual funds and/or exchange traded funds (“ETFs”), our Tax Overlay Management services are generally applied on the portion of your account containing equity securities and not to the portion that consists predominantly of mutual funds and/or ETFs. We generally accept tax gain and loss harvesting requests from Financial Advisors for accounts receiving Tax Overlay Management services, subject to certain limitations, such as amount, timing and the potential effect on transactions in the accounts. The details of gain and loss harvesting are agreed to between us and your Financial Advisor. You should contact your Financial Advisor for specific information. For clients with pooled investment vehicles, such as mutual fund holdings, acquired prior to 2012, we will rely on cost basis information provided by the Adviser and/or client as the basis for our tax analysis. We will make best efforts to realize capital gains within parameters set by the Adviser and/or client. Noting, however, that due to incomplete or uncertain cost basis information for pooled investment holdings acquired prior to 2012, there is no assurance that Symmetry tax overlay or tax loss harvesting programs will be able to limit capital gains exposure within agreed upon parameters. By default, accounts are managed without Tax Overlay Management Services unless specifically elected by your Financial Advisor.
• Referral to Third-Party Products As part of the Axiom program, Symmetry provides access to third-party investment solutions in spaces where it does not have a proprietary solution at this time. In some cases, Symmetry offers Models that wrap third-party solutions with a completion portfolio to arrive at a fully asset-allocated solution. Third-party solutions may be fully administered by the third-party provider or managed by Symmetry. Symmetry often receives a referral fee on third-party solutions. Symmetry Structured Portfolios Available through Symmetry’s Retirement Program, the Symmetry Structured Portfolios are a suite of non-tax-managed and tax-managed asset allocation portfolios comprised of open- end mutual funds and exchange traded funds. The Symmetry Structured Portfolios are comprised of an equity and fixed income allocation, which are designed to be systematic, broadly diversified, low cost and tax efficient. The equity portion of each Symmetry Structured Portfolio provides exposure across global equity asset classes to provide a high level of diversification, including allocations to the United States, international developed markets and emerging markets. Symmetry updates the allocations from time to time based on strategic long-term considerations. Clients are rebalanced periodically to maintain their desired equity to fixed income allocation and put the allocation back to or near the current target for their portfolio. The goal of each portfolio’s fixed income position is to mitigate the risk taken in the equity positions, while prudently capturing market-based fixed income returns. Therefore, the bond positions vary across model allocations. Symmetry Evolution Portfolio Offered only within the Symmetry Retirement program, the Evolution Portfolios are target date versions of the Structured Portfolios that feature an automatic rebalance of the equity to fixed allocation in the client’s account. Starting out as a 100/0 non-tax-managed Structured Portfolio, the Evolution Models will ratchet down the equity allocation in five-year increments until reaching the final stage, at which the model features a 30/70 equity to fixed income mix. The Evolution Portfolios are designed to accommodate clients as they age, and/or get closer to withdrawing their assets and, therefore, wish to gradually reduce their equity risk exposure over time. IndexElect IndexElect is a list of asset class funds recommended by Symmetry Partners as suitable complements to Symmetry Structured Portfolios. The list of funds has been compiled to provide sponsors of qualified plans with access to broad asset classes; in some cases, they represent asset classes that are either not available or are underweighted within the Symmetry Structured Portfolios. Collaborations with Unaffiliated Registered Investment Advisers Symmetry may collaborate with unaffiliated RIAs to offer a customized suite of portfolios to mutual clients. The RIAs that Symmetry may choose to collaborate with are subject to highly selective criteria. Symmetry utilizes its standard due diligence process, analysis, and investment principles to select the mutual funds and ETFs used in creating these portfolios. Please note, as this is a collaborative effort, Symmetry may need to work within additional constraints and objectives imposed or recommended by the RIA. The unaffiliated RIA’s services include, but are not limited to, establishing prospective client or client suitability, periodic contacts with clients, answering client inquiries, meeting with or contacting the client at least annually to ascertain if there is a change in the client's financial situation, updating client information, and monitoring client accounts. Symmetry's services include, but are not limited to, teaming with RIA on portfolio construction, research, trading, back office operations, account maintenance, and assisting IARs in servicing the clients. Investment Advisory Services As noted above, Symmetry provides investment advisory services to clients who are brought to Symmetry through investment adviser and registered representatives of the BD/RIAs. The BD/RIAs will either act in a promotor or co-advisor capacity depending on the agreement the BD/RIA has in place with Symmetry. For additional information about the promotor relationship please see item 14 of this brochure. Generally, the BD/RIA representatives introduce and assist the client in establishing a relationship with Symmetry Partners. The services include periodic contacts, answering client inquires, updating client information, meeting with or contacting the client at least annually to determine if there is a change in the client’s financial situation, and assisting the prospective client in understanding the services provided by Symmetry. Symmetry’s internal and external wholesalers assist the BD/RIA representatives with these services. The client suitability is determined through the use of various documents that may include, but are not limited to, the BD/RIA representative’s communication, correspondence, suitability documentation, and Symmetry’s Investment Policy Statement or Statement of Investment Selection. All forms of suitability are used to determine the client’s investment objectives, time horizon, tax considerations, income needs, and risk tolerance in order to determine the Symmetry Portfolio appropriate for the client. Symmetry offers investment advisory services to clients that have come to the firm through the efforts of the firm’s own IARs, labeled “direct clients.” The firm’s IARs assist Symmetry’s clients in determining which of Symmetry’s model portfolios is most appropriate, including customized portfolios to fit unique client needs and circumstances. Symmetry’s services may include the following: reviewing the client’s investment portfolio at the commencement of its relationship; assessing the client’s investment needs and objectives; investment policy planning and suitability; developing an asset allocation strategy designed to meet client objectives; ongoing monitoring of the performance of the accounts; reviewing accounts to ensure adherence to policy guidelines and rebalancing asset allocations when Symmetry, in its discretion, deems such re-balancing appropriate; answering client inquiries; updating client information; and, interviewing the client at least annually to determine if there has been a change in the client’s financial situation. Symmetry permits clients to maintain certain securities in their advisory account(s) that are not recommended by Symmetry. For these securities, Symmetry IARs will provide consultation services, which consist of general guidance on how those assets fit into the client’s overall financial objectives. Financial Planning Symmetry also provides advice in the form of a financial plan to a limited number of legacy clients. This service is not a standalone service for a separate fee, but part of the established bundle of services and an agreed upon fee charged to each client. The direct client may receive a written financial plan, designed to achieve the client’s stated financial goals and objectives. Implementation of financial plan recommendations is entirely at the client’s discretion. In general, the financial plan may address any or all of the following areas of concern:
• PERSONAL: Family records, budgeting, personal liability, estate and financial goals.
• TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years.
• RETIREMENT: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.
• INVESTMENTS: Analysis of investment alternatives and their effect on the portfolio. Symmetry Retirement Program Symmetry is an Investment Manager as defined in Section 402(c)(3) and 3(38) of the Employment Retirement Income Security Act of 1974 (“ERISA”) Symmetry works with a select group of third-party administrators (“TPAs”), referred to as Symmetry’s QP Partners. Symmetry offers its investment management services to 401(k) and qualified plans through the Symmetry Retirement program. Symmetry will review investment options, recommend a portfolio structure, recommend appropriate changes in portfolio holdings and advise the Plan Sponsor in support of the Plan Sponsor’s fiduciary role under the Plan. Symmetry may also provide the following:
• Quarterly portfolio review and performance analysis;
• Review of asset allocation rebalancing; and/or
• Periodic discussion of changes in weightings of the asset allocations. Symmetry also makes available the Symmetry IndexElect Funds. The IndexElect Funds are a menu of index mutual funds that are available for a Plan Sponsor to include in addition to Symmetry’s Structured Portfolios. Symmetry’s oversight responsibility extends to the IndexElect Fund menu and Symmetry’s portfolios. Symmetry also provides services to plans which fall outside the scope of the Symmetry Retirement Program by providing investment advisory services for accounts called Outside Qualified Plans. These are individual participant accounts where the plan document allows participants to select an investment adviser or investments outside of those selected by the plan. In addition, Symmetry’s portfolios and advisory services can be accessed through custodial and RIA retirement platforms. In addition, Symmetry provides investment management services to defined benefit plans. For these plans, Symmetry is an investment manager as defined in Sections 402(c)(3) and 3(38) of ERISA. The Institutional Pension Plans The Firm offers investment management services to municipalities and corporate pension plans. These services include Investment policy design and review, standard and customized performance reporting, meeting presentations, asset allocation, analysis and design, and investment oversight, monitoring and evaluation, on a regular and continuous basis. Sub-Advisor/Model Manager Advisory Services Symmetry provides investment advisory services acting as a sub-advisor/model manager to/on various technology, broker-dealer, custodian, and RIA management platforms. The services Symmetry provides are as follows: portfolio design, asset allocation, and securities selection for investment portfolios/models to be used in advisor accounts. Based on investment analysis, Symmetry will monitor and recommend changes to portfolio models. Symmetry also provides wholesaling, marketing, and sales support to investment adviser and registered representatives who have access to these respective platforms. C. Individually Tailored Services and Reasonable Restrictions Clients may place reasonable restrictions on their accounts. In some cases, Symmetry will also customize portfolios to fit the unique needs and situations for clients. However, a restriction request may not be honored if it is fundamentally inconsistent with Symmetry’s investment philosophy, is counter to the client’s stated investment objectives, or would prevent the firm from properly servicing client accounts. It should be noted as relates to the Funds, Symmetry’s management cannot not be tailored to the individual needs of any particular investor. As such, those investors do not have the ability impose restrictions on Symmetry’s management. D. Wrap Fee Programs In addition to the advisory business described above, we also participate as a portfolio manager in wrap fee programs. Under the wrap fee programs, investment advice and costs of trade executions are provided to clients for an all-inclusive wrap fee. Under the existing wrap fee program, Symmetry’s management fee is separate from the advisor fee, with trading and custodial costs paid out of the advisory fee charged by the client’s financial advisor. There is no difference in the way clients’ assets are managed as described in this document, due to the wrap fee program. E. Assets Under Management Symmetry’s discretionary assets under management were approximately $5.8 billion as of 12/31/2023.