CSPIA is an SEC registered investment adviser and a limited liability company formed under the laws of, and headquartered in, the state of Virginia. Registration does not imply a certain level of skill or training. The Firm is a wholly owned subsidiary of CSPF. As of December 31, 2023, CSPIA had $4,764,298,985 in assets under management on a discretionary basis and $2,213,037,139in assets under management on a non-discretionary basis. CSPIA provides individualized non-discretionary and discretionary advisory services to various categories of institutional and individual clients who wish to participate in financial planning, separately managed accounts (“SMA”), mutual funds, closed-end funds, exchange-traded funds, annuities, fixed income, structured notes, and equities; or who want to invest in private equity funds or other alternative investment vehicles. All services described in this brochure begin with a consultation between you and a CSPIA Investment Adviser Representative (“Financial Advisor”, “Advisor” or “FA”) to review your investment objectives, financial situation, and risk tolerance. Depending on the investment program, you are asked to complete a Client Profile to document the results of this assessment. After review of your profile, working with the FA, you will determine which program is appropriate for your needs. Your FA will provide advisory services that may include allocation of assets among different classes, portfolio diversification, managing portfolio risk, portfolio monitoring evaluation, investment policy statement development, manager search and recommendation, financial planning, and other general economic and financial topics. Your FA will construct a portfolio of securities based on your individual needs, risk tolerance and investment objectives. Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, etc.), and all managed accounts will be maintained with an independent qualified custodian. Certain investment programs, whether offered directly through CSPIA or through a Third-Party Platform, offer investment products or utilize Sub-Managers affiliated with CSPIA. Services Offered CSPIA offers various services to clients through its advisory programs based on individual client needs including financial planning, and recommendations for separately managed accounts (“SMA”), mutual funds, closed-end funds, exchange- traded funds, annuities, fixed income, structured notes, equities, private equity funds, and other alternative investment vehicles. Other Types of Advisory Services Wrap Fee Programs Cary Street Partners FA Directed Wrap Program (“FA Directed Program”) CSPIA is the sponsor of the Cary Street Partners FA Directed Wrap Program which provides investment management services on a discretionary basis to each client. Our wrap fee program allows you to pay a single fee that covers advisory services, trade execution, custody, and other standard brokerage and investment services. Each FA develops well- diversified portfolios designed to match the client’s financial goals, needs, risk tolerance and financial situation. Your FA will recommend that you establish account(s) at Wells Fargo, Charles Schwab, Fidelity, or another qualified custodian offering this type of wrap program pricing. Ultimately, though, it is your decision to custody assets with one of these or another qualified custodian of your choosing. CSPIA is independently owned and operated and not affiliated with Wells Fargo, Charles Schwab, Fidelity, or any other qualified custodian. March 2024 Wrap Fee Brochure Part 2A Page 5 of 16 For certain FA Directed wrap fee programs custodied at Wells Fargo, the provisions of our FA Directed program are based on and related to certain wrap fee programs offered by Wells Fargo Advisors (“WFA”). CSPIA has an agreement with WFA, pursuant to which WFA provides advisory and/or other services with respect to certain wrap fee programs (“WFA Programs”) which are related to the Cary Street Partners FA Directed Program. Although WFA provides certain services to our FA Directed Program wrap clients where Wells Fargo is custodian, WFA’s policy is to have CSPIA and their other correspondent firms maintain the role of Sponsor. In addition to this Cary Street Partners Wrap Fee Brochure, please review the appropriate WFA Disclosure Brochure (Form ADV Part 2A Firm Brochure and Wrap Fee Brochure) for a complete description of the services, fee schedules and account minimums for these wrap fee programs. Clients will receive those WFA wrap fee program brochures directly from Wells Fargo. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account.
• For example, a wrap fee program is not suitable for all accounts, including, but not limited to, accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees.
• In order to evaluate whether a wrap (or bundled) fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. Cary Street Partners Asset Management LLC (“CSPAM”) Wrap Programs CSPIA offers clients discretionary management services through its affiliate CSPAM, a registered investment adviser. CSPAM provides investment strategy services and is the Portfolio Manager of various wrap fee programs, each sponsored by various unaffiliated, third-party registered investment advisers. Please review the CSPAM Firm Brochure (Form ADV Part 2A Firm Brochure) for a complete description of its services, fee schedules and account minimums regarding its wrap fee programs. CSPAM manages specific investment strategies in wrap fee programs for both non-discretionary Model and discretionary Wrap Account programs sponsored by unaffiliated financial institutions similar to its management of the same strategies implemented in its CSP Global portfolios for example. In both the Wrap Account/Model programs however, CSPAM personnel primarily support the financial institution sponsoring the wrap program (“Sponsor”) and not the actual underlying client. There are fundamental differences between a Wrap Account and Model program. In a traditional Wrap Account program, a client selects the Sponsor. The Sponsor will work with the client to select an approved discretionary investment adviser, like CSPAM, for a particular investment strategy. From time to time, the Sponsor will communicate any specific client needs/requests to CSPAM, and CSPAM will evaluate for reasonableness within the strategy. CSPAM relies on the Sponsor to gather the necessary information and assess the suitability of its investment style to the individual needs and financial situation of a Wrap Account client. For Wrap Accounts, CSPAM exercises

investment discretion and delivers buy/sell instructions to the Sponsor’s platform. The Sponsor is responsible for execution of each transaction in the client accounts. Under the Model programs, depending on the model, the Sponsor or its designated representative, sometimes referred to as an “overlay manager,” exercises investment discretion and executes each client’s portfolio transactions based on March 2024 Wrap Fee Brochure Part 2A Page 6 of 16 the Sponsor’s own investment judgment. CSPAM does not tailor the model portfolio to the individual needs of any program client. CSPAM does not evaluate suitability for clients in a Model program. In both types of wrap programs, the Sponsor provides a bundle of services for a single fee. Typically, this bundle of services includes the review and monitoring of selected investment advisers approved in the program, performance evaluation of the advisers, execution of the client’s portfolio transactions, custodial services for the client’s assets, and payment of CSPAM’s advisory fee and other fees that may be charged in the Sponsor’s program. Fees and Compensation Wrap Fee Programs In most cases, the wrap fee program fees are negotiable. However, certain WFA wrap fee programs have household minimums that cannot be waived or negotiated. Please review the appropriate WFA Firm and Wrap Fee Disclosure Brochures (Form ADV Part 2A) for a complete description of the services, fee schedules and account minimums for WFA’s wrap fee programs and any related FA Directed programs. CSPIA has the option of setting up your account as Transactional-Based Pricing or Asset-Based Pricing with certain custodians.
• Transactional-Based Pricing-- CSPIA pays the transaction cost for each executed trade in such wrap fee accounts. As a result, we have a financial incentive to limit orders for wrap fee accounts because trades increase our transaction costs. Therefore, an incentive exists to trade less frequently in a wrap fee program with this pricing structure. We may charge clients higher advisory fees based on their trading activity, but you should be aware that we have an incentive to limit our trading in your account because we are charged for executed trades.
• Asset-Based Pricing-- CSPIA pays a single asset-based fee in lieu of transaction-based commissions. The fees we pay are assessed on certain assets in your account, including stocks, bonds, and certain mutual funds. If there is limited or no trading activity in your account, we will receive more compensation from your participation in our wrap fee program with this pricing structure than if you purchased our advisory services and custodian services separately. A wrap fee is not based directly on the number of transactions in your account. Various factors influence the relative cost of our wrap fee program to you, including the cost of our investment advice, custody and brokerage services if you purchased them separately, the types of investments held in your account, and the frequency, type and size of trades in your account. The wrap fee program could cost you more or less than purchasing our investment advice and custody/brokerage services separately. Our wrap fee covers our advisory services and the brokerage services provided by your qualified custodian including custody of assets, equity trades, ETFs, and agency transactions in fixed income securities. As a result, we have an incentive to execute transactions for your account with your qualified custodian. Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include the following: charges imposed directly by a mutual fund, index fund, or exchange-traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses); mark-ups and mark-downs; spreads paid to market makers; fees (such as a commission or markup) for trades executed away from your qualified custodian at another broker-dealer; wire transfer fees; and other fees and taxes on brokerage accounts and securities transactions. March 2024 Wrap Fee Brochure Part 2A Page 7 of 16 When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap (or program) fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. Other Advisory Services Fees and Revenue Sharing Our advisory services do not impose performance-based fees. Fees are based on the value of the assets in your account, and CSPIA shall not be compensated on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of client (i.e., performance-based fee). CSPIA may assess fee minimums and certain flat or fixed fee pricing arrangements which sometimes exceed 2% of the total assets under management and are higher than fees charged by certain other advisers that provide the same or similar services. Revenue Sharing within Cash Sweep Programs (the "Sweep Programs"): Uninvested cash balances in your account – for which no interest is otherwise earned or paid –are automatically swept into interest-bearing deposit accounts ("Bank Deposit Sweep") or, if available, money market mutual funds ("Money Market Funds") or such other sweep arrangements made available to you (collectively "Cash Sweep Vehicles"). Such balances remain in these sweep programs until they are invested by you or otherwise needed to satisfy obligations arising in connection with your account. CSPIA and our affiliates, in some cases, receive fees and benefits for services provided in connection with the Sweep Program, and we generally choose to make available the Cash Sweep Vehicles that are more profitable to us than other Money Market Funds or Bank Deposit Sweep accounts. A portion of these fees are paid to your FA. Lending Services – Interest Charges and Revenue Sharing For Wells Fargo products, a portion of the interest charged on the outstanding balances of margin loans or securities- backed lines of credit (“SBLOC”) will be paid to CSPIA, and solely with respect to an SBLOC, to your FA. An interest rate may be individually negotiated, instead of being based on the Wells Fargo Clearing Services (“WFCS”) base rate. Negotiated rates may have an expiration date, after which CSPIA/CSP may change your rate, without giving you any prior notice of the change, based on factors determined by CSPIA/CSP, in our sole discretion, including, without limitation, the account activity and our overall business relationship. For Goldman Sachs products, CSPIA and your Advisor have an incentive to recommend borrowing money on a client account, which represents a conflict of interest. A portion of the interest charged on the outstanding balance of your loan will be paid to CSPIA and to your Advisor. March 2024 Wrap Fee Brochure Part 2A Page 8 of 16