Firm Description Synergy Asset Management, LLC (“SAM,” “we,” “our,” or “us”) (formerly, Synergy Financial Management, LLC) is a Washington limited liability company founded in July of 2001. We provide personalized confidential financial planning and investment management to a variety of clients, including individuals, businesses, business owners, financial advisors, and trusts. Advice is provided through consultation with the client (“client,” “you,” or “your”) and may include: determination of financial objectives and goals, identification of financial issues, cash flow management, tax planning, investment management, education funding, retirement planning, and estate planning. Rowan Street Advisors, LLC (“Rowan”) is the Managing Member of Rowan Street Capital, LLC, an affiliated private fund. Crosslink Capital Group, LLC (“Crosslink”) is the sponsor and investment manager of a separate affiliated private fund, Crosslink Capital Fund I, LLC. Rowan, Crosslink (each a “Relying Advisor”), and SAM (as a “Filing Advisor”) are operationally integrated, collectively conduct a single advisory business, and are together filing a single Form ADV in reliance on guidance from the SEC and under the Investment Advisers Act of 1940 as amended (the “Act”). Relying Advisors are considered to be a registered investment advisor with the SEC and, as such, are required to comply with all the provisions of the Act and the rules thereunder that apply to registered advisors. Other related companies include Synergy Mergers + Acquisitions, LLC dba Synergy, a real estate broker working with many levels of real estate purchase and sales, and business consulting, which specializes in business planning, valuations, and succession strategies. SAM is also affiliated with Peace of Mind Planning, LLC dba AdvisorShare Wealth Management a Registered Investment Advisory Firm. Please see Item 10 for full details. Principal Owners SAM is owned 79% by Synergy Financial Services, Inc., 20% SFM2 LLC and 1% by Joseph M. Maas, our Principal. Mr. Maas owns 100% of Synergy Financial Services, Inc. Rowan Street Advisors, LLC is owned 50% by Alex Kopel and 50% by Synergy Financial Services, Inc. Crosslink Capital Group, LLC is owned 50% by Joseph M. Mass and 50% by Francis Roman. Types of Advisory Services SAM provides continuous and comprehensive wealth management and investment advisory services to our clients on a discretionary or non-discretionary basis, typically through managed accounts. We also provide co- advisory, family office, retirement plan advisory, and signal provider services, described further below. In addition, we provide asset management and investment advisory services to our private funds. The detailed terms, strategies, and risks applicable to investors in the funds are described in each fund’s organizational and offering documents. Tailored Advisory Services and Investment Options Through discussions with you, we develop a wealth management and investment plan based on, among other things, your particular circumstances, financial goals and/or objectives, risk tolerance, time horizon, and liquidity needs. We then implement the plan using internally managed custom portfolios we have developed. When providing advice, we may also recommend hiring third party investment managers for some of your assets. In certain situations, as appropriate, we may also recommend an investment in our private funds. Custom Portfolios As it relates to our custom portfolios, we manage most assets on a discretionary basis, meaning we have investment control to implement the plan we have developed with you without obtaining your consent prior to making a trade. Portfolios managed on a discretionary basis will strictly adhere to actively managed and monitored portfolios without the ability to influence the underlying security selection. We also manage portfolios on a non-discretionary basis, meaning we will manage and implement the plan we have developed with you, but will always obtain your approval prior to making any trades. You may impose reasonable restrictions on non-discretionary account(s), such as prohibiting the purchase of tobacco stocks, for example. We only make recommendations to advisory clients regarding investing in our private funds on a non- discretionary basis, meaning that you must decide whether to accept or reject our recommendations. For our private funds, this generally involves investing a private fund’s assets in accordance with the fund’s organizational and offering documents. As part of our investment process, we will also review any current investments you own and evaluate them in light of your current goals and objectives and offer our recommendations as to whether such investments should be retained. Financial Planning As requested, we provide comprehensive financial planning services as part of our services, and in connection with our broader investment management implementation, which may include:  A net worth statement  A cash flow statement  A review of investment accounts, including an asset allocation review and the provision of reposition recommendations  Strategic tax planning  A review of retirement accounts and plans, including recommendations  A review of one or more retirement scenarios  An estate planning review and recommendations  Education planning with funding recommendations For clients with extraordinary financial planning needs, we offer our family office services, which can include one or more of the above services, as well as coordination planning and financial-related information with the client’s other professional advisers, including the client’s attorney(s) and accountant(s). To the extent required, accounting and legal services are provided by unaffiliated third-parties, not subject to our supervision or oversight. Retirement Plan Advisory Services We may be engaged to provide investment advisory and consulting services to participant-directed retirement plans. For such engagements, we can assist the plan sponsor with the selection of an investment platform, as well as a broadly diversified menu of investment alternatives from which plan participants can select to make their investment choices (which may include investment strategies devised and managed by our firm), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision making process. Services to Third-Party Advisors Asset Management SAM provides discretionary portfolio management services to third party unaffiliated investment advisors (“TPIAs”). In most cases we also provide asset management services such as investment research and model portfolios, as well as handling account administration, billing and reporting on behalf of the TPIA. The specific services provided to a given TPIA are specified in an agreement between SAM and the TPIA. If applicable, clients of the TPIA will enter into a tri-party agreement with SAM and the TPIA that describes the services to be provided by each entity, as well as the fees payable to each for their respective services. In general, SAM provides only investment management services when working with clients in a tri-party agreement; the TPIA is typically responsible for all other services, such as financial planning, insurance planning, retirement and IRA rollover planning, and other financial services. Management Services to Other Advisors and Institutions We also have relationships with TAMPs, custodians and unaffiliated investment advisors in which we provide model portfolios, signal provider services, and/or suggested allocations on an impersonal basis. In these cases, the end client is typically not a client of SAM and will not enter into an advisory agreement with us. Clients using these services will receive applicable disclosure documents through the TAMP, custodian, or unaffiliated investment advisor. SAM has no obligation to determine client suitability and has no control over the timing of trading in end client accounts maintained through these other financial institutions. Where SAM acts as a co-manager with another advisor and creates a client relationship, we will enter into an advisory agreement with the end client that specifies our services and fees, as well as those of the other manager. Our agreements with other financial institutions (such as FOLIOfn, Nationwide, and Adhesion) to provide models or allocations do not create an advisor-client relationship between SAM and end investors. We also serve as a sub-adviser to unaffiliated registered investment advisers. The unaffiliated investment advisers that engage us for sub-advisory services shall maintain both the initial and ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of client suitability for our designated investment strategies. If the custodian/broker-dealer is determined by the unaffiliated investment adviser, we will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by our firm. Higher transaction costs adversely impact account performance. Investment Committee On a very limited basis, we may also partner with other unaffiliated investment advisors to form an investment committee. In such arrangements, the committee will meet on a regular basis to share information regarding market trends, investment strategies, research findings, and other topics related to the management of client accounts. The committee does not discuss any specific client accounts, and each member of the committee maintains exclusive responsibility for ensuring that any actions taken with respect to client accounts are in accordance with that client’s designated investment objective and any applicable restrictions. Members of the investment committee are under absolutely no obligation to accept or implement any trading concepts and/or strategies discussed by the committee. SAM’s Chief Compliance Officer, Todd Jessup, remains available to address any questions that a client or prospective client may have regarding this investment committee arrangement. Assets Under Management As of December 31, 2023, our total regulatory assets under management (including Separately Managed Accounts) were approximately $810.2 million all of which is managed on a discretionary basis. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: To the extent requested by a client, SAM may provide financial planning and related consulting services regarding non- investment related matters, such as estate planning, tax planning, insurance, etc. for a separate fee per the terms and conditions of a Financial Planning and Consulting Agreement between SAM and the client. Please Note: SAM does not serve as an attorney or accountant, and no portion of our services should be construed as legal or accounting services. Accordingly, SAM does not prepare estate planning documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including certain of SAM’s own representatives, in their separate individual capacities as licensed insurance agents of SAM’s affiliated insurance agency, Synergy Financial Services, Inc. (“SFS”). 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 SAM and/or its representatives. Please Note: If the client engages any recommended unaffiliated 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-Conflict of Interest: A recommendation by SAM that a client purchase an insurance commission product from SAM’s representatives in their separate individual capacities as licensed insurance agents, including as agents of SFS presents a conflict of interest, as the receipt of commissions provides an incentive to recommend investment products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any insurance commission products from SAM’s representatives or SFS. Clients are reminded that they may purchase insurance products recommended by SAM through other, non-affiliated insurance agents and agencies. SAM’s Chief Compliance Officer, Todd Jessup, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. 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 tax consequences). If Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. No client is under any obligation to rollover retirement plan assets to an account managed by SAM. SAM’S Chief Compliance Officer, Todd Jessup, 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. Fiduciary Acknowledgment: When SAM provides investment advice to a client regarding the client’s retirement plan, retirement plan account, or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way SAM makes money creates some conflicts with client interests, so SAM operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule's provisions, SAM must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that SAM gives advice that is in the client’s best interest;
• Charge no more than is reasonable for SAM’s services; and
• Give the client basic information about conflicts of interest. Charles Schwab and Interactive Brokers: As discussed below in Item 12, unless the client directs otherwise, SAM shall generally recommend that Charles Schwab (“Schwab”) and/or Interactive Brokers, LLC (“IB”) serve as the broker-dealer and/or custodian for client investment management assets. Broker-dealers and custodians generally charge brokerage commissions and/or transaction fees for effecting securities transactions. In addition to SAM’s investment management fee described at Item 6 below, brokerage commissions and/or transaction fees, 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 Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client can obtain many of the mutual funds that may be recommended and/or utilized by SAM independent of engaging SAM as an investment advisor. However, if a prospective client determines to do so, he/she will not receive SAM’s initial and ongoing investment advisory services on that fund. Please Note: Asset Based Pricing Limitations: We may recommend that our clients enter into an asset-based pricing agreement with the account custodian. Under an asset-based pricing arrangement, the amount that a client will pay the custodian for account commission/transaction fees is based upon a percentage (%) of the market value of your account, generally expressed in basis points. One basis point is equal to one one-hundredth of one percent (This differs from transaction-based pricing, which assesses a separate commission/transaction fee against your account for each account transaction. Account investment decisions are driven by security selection and anticipated market conditions and not the amount of transaction fees payable by you to the account custodian. We do not receive any portion of the asset-based transaction fees payable by you to the account custodian. We continue to believe that our clients can benefit from an asset-based pricing arrangement. You can request at any time to switch from asset-based pricing to transaction-based pricing, However, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Thus, given the variances in trading volume, any decision by you to switch to transaction-based pricing could prove to be economically disadvantageous. ANY QUESTIONS: Our Chief Compliance Officer, Todd Jessup, remains available to address them. Periods of Portfolio Inactivity. SAM has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, SAM will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when SAM 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 SAM will be profitable or equal any specific performance level(s). Clients remain subject to SAM’s ongoing investment advisory fees, even during these periods of portfolio inactivity. Please Note: Non-Discretionary Service Limitations. Clients who engage SAM on a non-discretionary investment advisory basis must be willing to accept that SAM cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that SAM would like to make a transaction for a client's account (including in the event of an individual holding or general market correction), and the client is unavailable, SAM will be unable to effect the account transaction(s) without first obtaining the client’s consent. Separate Managed Account program engagements: As indicated above, SAM’s investment strategies are available on unaffiliated managed account programs. In these type of arrangements, unaffiliated investment professionals can determine to allocate a portion of their clients’ assets to one or more SAM strategies. In these type of arrangements, SAM may be directed to effect account transactions though a specific broker- dealer/custodian, and SAM will correspondingly be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative brokerage/custody arrangements. Higher transaction costs adversely impact account performance. If SAM is engaged in conjunction with an unaffiliated a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately. Please Note: Transactions for program directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. Introduction from Unaffiliated Investment Professionals. If the client obtains SAM services through the client’s Investment Professional (i.e., broker or adviser), the Investment Professional shall serve as the client’s primary investment professional, and shall be exclusively responsible for: (a) assisting client in determining the initial and ongoing suitability for the SAM’s investment portfolios and/or strategies; and, (b) for receiving/ascertaining client’s directions, notices, and instructions, and forwarding them to SAM in writing. SAM shall be entitled to rely upon any such direction, notice, or instruction until it has been duly advised in writing of changes therein. SAM’s obligation shall be to manage the assets consistent with the investment strategy directed by the Investment Professional. SAM shall have no responsibility to the client for the failure of the Investment Professional to timely receive/ascertain/forward/communicate any and all such directions, notices, and instructions. If SAM is directed by the Investment Professional to effect account transactions though a specific broker-dealer/custodian, SAM will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative brokerage/custody arrangement. Higher transaction costs adversely impact account performance. Please Note: Transactions for program directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. Private Investment Funds and DST Investments. As indicated below, SAM may also provide investment advice regarding affiliated and unaffiliated private investment funds, including real estate Delaware Statutory Trusts (“DSTs”). SAM, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds and/or DSTs. With respect to unaffiliated private investment funds and DSTs, SAM’s role shall be limited to its initial and ongoing due diligence and investment monitoring services. Unless indicated to the contrary, in writing, if a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of SAM calculating its investment advisory fee. With respect to DST investments, such investments shall not be included in the client’s assets under management for the purposes of SAM calculating its advisory fee. Rather, DST investments shall be assessed a distinct asset-based fee, which fee shall be separate from, and in addition to, SAM’s standard investment advisory fee as set forth in Item 5 below. SAM’S clients are under absolutely no obligation to consider or make an investment in a private investment fund(s) and/or DST(s). Please Note: Private investment funds and DSTs, 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 and DSTs 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 and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that SAM references private investment funds or DSTs owned by the client on any supplemental account reports prepared by SAM, the value(s) for all such investments shall reflect the most recent valuation provided by the fund or DST sponsor. If no subsequent valuation post-purchase is provided, then the valuation shall reflect the initial purchase price (and/or a value as of a previous date), or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund or DST sponsor). If the valuation reflects initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than original purchase price. The client’s advisory fee shall be based upon reflected fund value(s). Please Also Note: Private Fund Conflict of Interest. Because SAM can earn compensation from affiliated private investment funds (both management fees and incentive compensation) that may exceed the fee that SAM would earn under its standard asset-based fee schedule referenced in Item 5 below, the recommendation that a client become a private fund investor presents a conflict of interest. No client is under any obligation to become a private fund investor. SAM’s Chief Compliance Officer, Todd Jessup, remains available to address any questions regarding this conflict of interest. Please Also Note: DST Conflict of Interest. SAM does not include real estate in assets under management for the purposes of calculating its standard advisory fee. However, SAM is entitled to an asset-based fee for DST investments, as set forth in Item 5 below. Therefore, by recommending a client sell a real estate asset in order to invest the proceeds in a DST, SAM has a conflict of interest, as the recommendation could be based on the compensation to be received, rather than on a client’s best interest. No client is under any obligation to become a DST investor. SAM’s Chief Compliance Officer, Todd Jessup, remains available to address any questions regarding this conflict of interest. Client Obligations. In performing our services, SAM 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 on information received. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify SAM if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: 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 SAM) will be profitable or will attain any specific performance level(s). Cash and Cash Equivalent Positions. SAM treats cash as an asset class. As such, all cash and cash equivalent positions (e.g., money market funds, etc.) shall be included as part of assets under management for purposes of calculating the SAM’s advisory fee, unless otherwise agreed in writing. 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), SAM may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash, such amounts could miss market advances, and, depending upon current yields, at any point in time, SAM’s advisory fee could exceed the interest paid by the client’s money market fund.