A. Column Capital Advisors, LLC is an SEC registered Investment Advisory firm with the following officers: Brian W. Upchurch, President; Frank W. Tinsley, Chief Operating Officer, Kevin D. Sweet, Chief Investment Officer; and Jeffrey J. Yu, Chief Compliance Officer. Column Capital Advisors, LLC is 100% directly owned by Column Capital Group, Ltd. (the holding company), which in turn is owned by Brian Upchurch, Kevin Sweet and Jeffrey Yu. Formed in 2005, Column Capital Advisors, LLC (“Column Capital”) provides two types of fee- only advisory services for clients: Investment Management and Financial Planning. Both of these separate services are further described below, as well as in the agreement applicable to each service. The term “fee-only” means that Column Capital only receives compensation from its clients for the investment management (including investment consulting services) and financial planning services provided. Column Capital does not receive any commissions for assistance with the purchase of securities, insurance products or any other products. B. Column Capital provides their services primarily to high net worth individuals and their families. However, in some instances Column Capital may provide their services to retirement plans, pension and profit-sharing plans, trusts, estates, charitable organizations or other business entities. Discretionary Investment Management Services: The first step in the Investment Management process involves an initial interview and data gathering process. This is designed to help determine the client’s stated individual needs, financial/investment goals, objectives, time horizon and overall risk profile. The Advisor will request input and information from the client including current financial information, past financial history, present financial conditions and the client’s financial and investment goals. These may include planning for short-term goals (such as large asset purchases or college education funding), long-term goals (such as retirement planning) or other segments of an investment plan that may be desired. The information gathered for review and assessment may vary depending upon the individual needs and objectives as stated by the client. Information presented by the client is deemed to be current, reliable and complete. The Advisor may request the names and relationships of other Advisors (e.g., attorney, accountant, banker, etc.), family background and makeup, and anything else which may affect the client’s financial matters based upon the information provided by the client. Based upon the collected information and with the client’s input, the Advisor will prepare an investment policy statement (IPS) which includes a target investment portfolio allocation. The Advisor will consider various investment programs that may assist the client in meeting the client’s stated investment objectives. Column Capital prefers that the client implement their recommendations, in whole or in part, through Charles Schwab & Co., Inc. as the custodian. However, a different custodian can be used at the client’s request. Column Capital primarily implements trades on a discretionary basis but will accept non-discretionary accounts. Before engaging Column Capital to provide investment advisory services, clients are required to enter into the appropriate Investment Advisory Agreement with Column Capital setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. A client has the ability to leave standing instructions with Column Capital to refrain from investing in particular industries, invest in limited amounts of securities, sell, request third-party checks (sent from the custodian directly to the client’s address of record), request electronic fund transfers and re-balance portfolios. Clients will have a direct and beneficial interest in clients’ securities rather than an undivided interest in a pool of securities. In most instances, Column Capital utilizes mutual funds and exchange traded funds (ETFs) for client portfolios. Clients may also own individual stocks and bonds through the use of Third- P a r t y managers. Column Capital encourages frequent client contact (i.e., two to three times per year) but will seek out contact no less than annually depending upon the client’s situation or desires. Clients may call the office at any time during normal business hours to discuss investment matters directly with their Advisory Representative. If their Advisory Representative is unavailable, the client can ask for assistance from any Advisory Representative of Column Capital. The Advisor team consists of an Executive Director (lead role) and may include other professional and administrative staff with a common vision of serving Column Capital’s clients. Clients are obligated to promptly notify the Advisor of any changes in the client’s financial status in order to give the firm an opportunity to review the current investment strategies designed for the client to ensure they continue to meet the client’s changing needs or to determine if there needs to be any changes. For accounts invested in mutual funds and ETFs, the direct investment management fees paid to Column Capital are in addition to the indirect management and expense fees charged by mutual funds and ETFs. Therefore, clients whose assets are invested in shares of mutual funds and ETFs will incur both an investment management fee paid directly to Column Capital and management fees and operating expenses collected indirectly through the mutual fund or ETF. As a fee only advisor, Column Capital uses no load mutual funds. As a result, Column Capital does not receive any commissions or 12b-1 fees from any mutual fund companies. Use of Third-Party Investment Management Firms If appropriate and of interest to the client, Column Capital will recommend the services of one or more unrelated third-party investment advisory firms or private money manager (“Independent Manager”) that may offer investment advisory services designed to help clients meet their stated goals and objectives. The decision to hire an Independent Manager is influenced by the account size, client’s circumstances and costs. Column Capital would provide recommendations only as a service to clients and will not receive any direct or indirect compensation for recommendations (no “referral fees”). At the time of the recommendation of any Independent Manager, Column Capital will deliver to a client the private money manager’s Firm Disclosure Brochure and any other information required by Investment Advisers Act. Clients are welcome to engage any outside investment manager of their choice and there would never be an obligation to do so. Any engagement of an Independent Manager would be entered into with a separate contract or agreement between the client and the Independent Manager and will include a separate fee arrangement that the client will be paying this third-party advisor. This fee is in addition to the fees paid by the client to Column Capital. Clients are never under any obligation to utilize the third-party products or services that may be recommended. As a client, you will receive separate documents from these Independent Manager regarding their services. These include a complete description of their programs, services, fees, payment structures and termination features in their separate disclosure brochures, investment advisory contracts and account opening documents. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. Once we determine the most suitable Independent Manager for the client, we provide the selected manager(s) with the client's information. The Independent Manager then creates and manages the client's portfolio based on the client's individual needs. Clients should refer to the Independent Manager's Firm Disclosure Brochure or other disclosure document for a full description of the services offered. Client meetings are available on a regular basis, or as designated in the contractual agreement with the client and our firm, to review the account. As your management advisor, we will monitor the performance of the selected Independent Manager(s). If we determine that a particular selected Independent Manager (s) is not providing sufficient management services to the client or is not managing the client's portfolio in a manner consistent with the client's goals and objectives, we will suggest that the client contract with a different Independent Manager and/or program sponsor. Under this scenario, our firm assists the client in selecting a new manager and/or program. Alternately, we may determine that the selected Independent Manager is not performing consistent with our expectations and select a new manager and/or program sponsor without obtaining the client’s prior consent. Column Capital generally considers the following factors when considering its recommendation to allocate investment assets to Independent Manager(s): the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Column Capital also engages the third-party due diligence firm, Segal Rogerscasey, a division of Segal Advisors, to assist Column Capital in remaining up to date as to interim material developments affecting any Independent Manager. Column Capital has relationships with one or more unaffiliated third-party investment advisory firms (private money managers) that provide investment advisory services that may be of interest to clients. When it is deemed appropriate, based upon the individual needs of the client, Column Capital may recommend that clients engage one or more Independent Manager who provide advice regarding the selection of individual securities (i.e., stocks, bonds). In such cases, Column Capital remains the primary Advisor and Investment Manager for its clients and receives no compensation from the referral to the unaffiliated Independent Manager or Advisors. Any engagement of an Independent Manager or investment advisory firm under this type of referral would be undertaken with a separate contract or agreement between the client and the unaffiliated Independent Manager and will include a separate fee arrangement that the client will be paying the third- party investment advisor. This fee is in addition to the fees paid by the client to Column Capital. Clients are never under any obligation to utilize the third-party products or services that may be recommended. Other Investment Consulting: At the client’s specific request, Column Capital will link a client’s unaffiliated managed account to our reporting systems in order to provide investment consulting by way of a review of the performance of the non-managed portfolio. Our firm will provide advice and recommendations to the client, if requested. Although we provide a review of the investments of the specific manager, Column Capital does not perform due diligence of the manager and has not made a recommendation or referral of such manager. In addition, Column Capital will provide specific consulting services based on a client’s needs and requests. These types of engagements are formalized in a written agreement with the client. Financial Planning Services: Column Capital’s Financial Planning Services are comprehensive in nature and cover many areas of financial and tax planning. The services provided to each client are integrated and customized to address their specific issues and help clients meet their financial goals and objectives. Financial Planning Services may address issues relating to the following areas: Goals, Net Worth and Estate Summary, Cash Flow Planning, Income Tax Planning and Projections, Company Benefits, Retirement Planning, Estate and Wealth Transfer Planning, Insurance Analysis and Review, Education Funding, Mortgage and Debt Financing, Charitable Giving and other needs as identified by the client. To the extent requested by a client, Column Capital will offer comprehensive planning services, or provide advice in a specific financial planning area. Column Capital can tailor services as desired by the client. When Financial Planning Services only focus on certain areas of client interests or needs, the Client must understand that their overall financial situation or needs may not be addressed. To the extent requested and engaged by the client to do so, Column Capital will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. per the terms and conditions of a separate agreement and a separate fee as discussed at Item 5 below, the fee for which shall be based upon the individual providing the service and the scope of the services to be provided. Prior to engaging Column Capital to provide planning or consulting services, clients are generally required to enter into a Financial Planning Agreement with Column Capital setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Column Capital commencing services. If requested by the client, Column Capital may recommend the services of other professionals for implementation purposes including our affiliated accounting firm (under common ownership and control), Column Family Office, LLC (“Family Office”) for tax preparation and accounting-related services. If a client determines to engage Family Office, he/she does so per the terms and conditions of a separate written agreement between Family Office and the client, to which Column Capital is not a party. There is no fee-sharing arrangement between the Family Office and Column Capital. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Column Capital and/or its representatives. The recommendation by Column Capital representative that a client engage Family Office for tax preparation and/or accounting-related services, presents a conflict of interest because Column Capital’s affiliate will derive additional compensation from such engagement. No client or prospective client is obligated to engage Family Office. Column Capital will work with the tax professional of the client’s choosing. Column Capital believes that it is important for the client to address financial planning issues on an ongoing basis. 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 Column Capital. 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 Column Capital, shall be responsible for the quality and competency of the services provided. The advice provided may include recommendations for regular updates and reviews. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Column Capital will provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Column Capital does not serve as an attorney or accountant, and no portion of its services should be construed as legal or accounting services. As noted above, Column Capital provides financial planning services in connection with its Investment Advisory Services. Accordingly, Column Capital does not prepare estate planning documents. As noted above, any assistance with tax preparation is outsourced to a third-party firm at no additional cost to the client for a basic tax return. To the extent requested by a client, Column Capital may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance agents, etc.). 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 Column Capital and/or its representatives. 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. At all times it is the engaged licensed professionals (i.e., attorney, accountant, insurance agent, etc.), and not Column Capital, that is responsible for the quality and competency of the services provided. Column Capital’s Chief Compliance Officer, Jeffrey Yu, remains available to address any questions that a client or prospective client has regarding the above conflict of interest. Non-Discretionary Service Limitations. Clients that determine to engage Column Capital on a non-discretionary investment advisory basis must be willing to accept that Column Capital cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that Column Capital 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, Column Capital will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Availability of Mutual Funds and Exchange Traded Funds: Column Capital utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Column Capital’s investment advisory fee described below, and transaction and/or custodial fees discussed below, 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). Column Capital 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 Column Capital’s 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. Column Capital’s Chief Compliance Officer, Jeffrey Yu, remains available to address any questions that a client or prospective client has regarding the above. Independent Managers: Column Capital may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers or separately managed accounts in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets. Column Capital shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Column Capital shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is separate form, and in addition to, Column Capital’s advisory fee as set forth in Item 5. Client Obligations. In performing its services, Column Capital 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 their responsibility to promptly notify Column Capital if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Column Capital’s previous recommendations and/or services. Retirement Plan Rollovers – No Obligation / 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 Column Capital recommends that a client roll over their retirement plan assets into an account to be managed by Column Capital, such a recommendation creates a conflict of interest if Column Capital will earn a new (or increase its current) advisory fee as a result of the rollover. If Column Capital 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), Column Capital 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 Column Capital. Column Capital’s Chief Compliance Officer, Jeffrey Yu, remains available to address any questions that a client or prospective client has regarding the conflict of interest presented by such a rollover recommendation. Portfolio Activity. Column Capital has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Column Capital 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, financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when Column Capital determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, there can be no assurance that investment decisions made by Column Capital will be profitable or equal any specific performance level(s). Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Cash Positions. Column Capital continues to treat cash as an asset class. As such, unless determined to the contrary by Column Capital, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Column Capital’s 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), Column Capital 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, Column Capital’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, Registrant shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless Registrant reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Jeffrey Yu, remains available to address any questions that a client or prospective client may have regarding the above. ByAllAccounts/eMoney/Black Diamond. Column Capital, in conjunction with the services provided by “ByAllAccounts,” “eMoney,” and/or “Black Diamond” may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by Column Capital (the “Excluded Assets”). The ByAllAccounts/eMoney/Black Diamond platform allows a client to view their complete asset allocation, including those assets that Column Capital does not manage (the “Excluded Assets”). Column Capital does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, Column Capital shall not be responsible for the investment performance of the Excluded Assets. The client and/or their other advisors that maintain trading authority, and not Column Capital, shall be exclusively responsible for the investment performance of the Excluded Assets. In addition, eMoney also provides access to other types of information, including financial planning concepts, which should not be construed as services, advice or recommendations provided by Column Capital. Column Capital does not provide investment management, monitoring or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, Column Capital’s service relative to the Excluded Assets is limited to reporting only. Column Capital does not maintain any trading authority over the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If Column Capital were asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Column Capital shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Column Capital provide investment management services for the Excluded Assets, the client may engage Column Capital to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Column Capital and the client. Other Assets. To the extent that the Registrant provides advisory monitoring or review services for client investment assets for which the Registrant does not maintain custodian access or trading authority (including initial and ongoing consideration of such assets as part of the client’s asset allocation), the Registrant may determine to include such assets in its advisory fee calculation per Item 5 below. 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 or
• 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, Column Capital does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new residence). Column Capital 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 Column Capital:
• by taking the loan rather than liquidating assets in the client’s account, Column Capital continues to earn a fee on such Account assets;
• if the client invests any portion of the loan proceeds in an account to be managed by Column Capital, Column Capital will receive an advisory fee on the invested amount; and,
• if Column Capital’s advisory fee is based upon the higher margined account value (see margin disclosure at Item 5 below), Column Capital will earn a correspondingly higher advisory fee. This could provide Column Capital 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 loans. 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 Registrant) will be profitable or equal any specific performance level(s). Cybersecurity Risk. The information technology systems and networks that Registrant and its third-party service providers use to provide services to Registrant’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Registrant has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Registrant does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Disclosure Brochure. A copy of Column Capital’s written Privacy Policy, Brochure as set forth on Parts 2A and 2B of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client or prospective client prior to, or contemporaneously with, the execution of the applicable form of agreement between Column Capital and the client. Any client who has not received a copy of Column Capital’s written Brochure at least 48 hours prior to executing such agreement shall have five business days subsequent to executing the agreement to terminate Column Capital’s services without penalty. C. Column Capital shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Column Capital 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 Column Capital’s services. D. Column Capital does not participate in a wrap fee program. E. As of December 31, 2022, Column Capital managed a total of $1,206,325,951 in Discretionary assets for client investment accounts and $52,703,962 in assets for Non-Discretionary client investment accounts for a total of $1,259,029,913 in assets under management.