Marcum Wealth, LLC, is an independent, fee-based, SEC-registered investment advisory and consulting firm, with its principal place of business located in Cleveland, Ohio with additional offices in Akron, Ohio; Mentor, Ohio; Hartford, Connecticut; Tampa, Florida; Melville, New York; Philadelphia, Pennsylvania; Chesterfield, Missouri; and, effective July 2023, Blue Bell, Pennsylvania. Guided by the Marcum Asset Allocation Frameworks, Marcum generally invests client assets among independent managers. Marcum may provide advice on client assets among mutual funds, exchange traded funds, independent separately managed accounts, hedge funds, managed futures, real estate investment trusts (REITs), individual debt and equity securities and/or options as well as the components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. Individuals / High Net Worth Individuals Family wealth management is a process built around the coupling of financial planning and asset management. Marcum views the two as inseparable components of a long-term successful strategy. At Marcum, each family we work with is unique, as their goals are defined by their life experiences and family circumstances. From helping clients invest their children’s first investment dollars to complex estate and business succession strategies, Marcum’s team of experienced and caring advisors works collaboratively with our clients to understand their life’s ambitions, then develop the right financial plan and corresponding investment strategies to achieve their goals. Marcum’s services to individuals and high net worth individuals can include discretionary and/or non-discretionary asset management. Marcum’s asset management services are customized based on the individual client’s needs. Prior to providing investment advice to new clients, a Marcum representative will meet with the prospective client to assess their needs, goals and objectives. Marcum’s focus during this process is on assisting the prospective client with determining their short-term and long-range investment goals and objectives. Upon completing the analysis, Marcum will work to determine an asset allocation strategy customized to the client’s financial goals, objectives, and risk tolerance. Once an asset allocation strategy is agreed upon, Marcum will customize the client’s portfolio allocation taking into consideration any limitations or restrictions, the market and economy at the time and the client’s financial situation, goals, and objectives. While clients can impose reasonable restriction on Marcum’s management of their accounts, Marcum tailors its advisory services to the individual objectives of clients depending on specific needs such as cash flows, liquidity, risk tolerance, return expectations, etc. After the client’s assets are initially allocated, Marcum will rebalance or provide rebalancing recommendations with respect to the client assets, considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. Marcum can also be engaged to provide discretionary or non-discretionary asset management over client assets held client retirement plan accounts, such as a 401(k) plan or SIMPLE IRA. For retirement plan accounts where Marcum has a direct relationship with the plan custodian (such as SIMPLE IRAs held through Capital Group and American Funds), Marcum can directly engage in account trading activity by communicating its desired allocations to the plan custodian for execution. For client assets where Marcum does not have a direct relationship with the custodian (including but not limited to employer sponsored retirement plan accounts), Marcum may use a third-party platform to facilitate discretionary or non-discretionary management. The platform allows Marcum to avoid being considered to have custody of client funds since the firm does not have direct access to client log- in credentials to affect trades. Marcum is not affiliated with the platform in any way and receives no compensation for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform. Once the client account(s) is connected to the platform, Marcum can begin rendering its asset management service. Client retirement account(s) will be reviewed at least annually, and allocation changes will be made or recommended as deemed necessary. When providing this service, Marcum will be limited to the investment alternatives provided by the retirement plan. Marcum will not have, nor will it accept, any authority to effect any other type of transactions or changes to the client’s plan account, including but not limited to changing beneficiaries or effecting account disbursements or transfers to any individual or entity. Marcum will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Marcum of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Marcum may also render non-discretionary advisory services to clients relative to variable life/annuity products that they may own. In so doing, Marcum recommends the allocation of client assets among the various mutual fund subdivisions that comprise the variable life/annuity product. In addition, Marcum provides an automated investment program (the “Program”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“Platform”) offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire investment strategy and portfolio. Clients should note that, if we use the online questionnaire, we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The system also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does receive other revenu es in connection with the Program. Marcum does not pay SPT fees for the platform. Marcum charges clients a fee for our services as described below under Fees and Compensation. Corporate Retirement Plans Marcum provides advisory and consulting services to company-sponsored employee retirement plans. Such plans include, but are not limited to, 401(k), profit sharing, defined benefit, cash balance, non-qualified, excess benefit, and deferred compensation plans. Our services focus on five key aspects of corporate retirement plans – fiduciary governance, investment management, plan design, employee education and vendor searches. The services that can be provided to different plan types and structures are described below. Trustee Directed Plans. Marcum may be engaged to provide investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Marcum will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Marcum will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. Participant Directed Retirement Plans. Marcum may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between Marcum and the plan. For such engagements, Marcum shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by Marcum), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Regardless of the type of plan, Marcum will engage with a plan sponsor (e.g., the client) as an investment fiduciary as defined in ERISA §3(21) and/or as an investment manager as defined in ERISA §3(38). As a 3(21)-investment fiduciary, Marcum makes investment recommendations to the plan sponsor, which is then responsible for accepting or rejecting Marcum’s recommendations. In this role, Marcum serves as a non- discretionary co-fiduciary. As a 3(38)-investment manager, Marcum can provide the same general services on a fully discretionary basis. In this role, Marcum serves as a discretionary full-scope fiduciary. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services Marcum will generally provide financial planning and related consulting services, such as tax and estate planning, insurance, etc. inclusive of its advisory fee set forth under Fees and Compensation below (exceptions may occur based upon assets under management, special projects, etc. for which Marcum may charge a separate fee, or a stand-alone financial planning engagement). Marcum does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as the same. Accordingly, Marcum does not prepare estate planning documents, tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals (e.g., attorneys, accountants, insurance agents, etc., including our related CPA firm, Marcum, LLP, as well as Marcum’s affiliated insurance firm, Marcum Insurance Services (see Other Financial Industry Activities and Affiliations). 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 Marcum and/or its representatives. If the client engages

any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. The recommendation by a Marcum representative that a client engage Marcum, LLP for accounting-related services including tax preparation or Marcum Insurance Services for insurance-related services or products, presents a conflict of interest, as the potential receipt of revenue by Marcum’s related party may provide an incentive to recommend Marcum, LLP’s accounting services or Marcum Insurance Services for insurance-related services or products. No client is under any obligation to engage Marcum, LLP for accounting and/or tax preparation services or Marcum Insurance Services for insurance-related services or products. Marcum will work with the accountant and insurance agent of the client’s choosing. Retirement Rollovers 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): (1) leave the money in the former employer’s plan, if permitted, (2) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (3) roll over to an Individual Retirement Account (“IRA”), or (4) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Marcum recommends that a client roll over their retirement plan assets into an account to be managed by Marcum, such a recommendation creates a conflict of interest if Marcum 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 Marcum. Fiduciary Acknowledgment When Marcum provides investment advice to a client regarding the client’s 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 Marcum makes money creates some conflicts with client interests, so Marcum 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, Marcum 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 Marcum gives advice that is in the client’s best interest.
• Charge no more than is reasonable for Marcum’s services; and
• Give the client basic information about conflicts of interest. Use of Mutual and Exchange Traded Funds Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by Marcum independent of engaging Marcum as an investment advisor. However, if a prospective client determines to do so, he/she/it will not receive Marcum’s initial and ongoing investment advisory services. In addition to Marcum’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). Independent Managers Marcum may allocate a portion of a client’s investment assets among unaffiliated independent investment managers 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. Marcum shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Marcum 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 from, and in addition to, Marcum’s advisory fee as set forth in the fee schedule listed below. Custodian Charges/Additional Fees As discussed below under Brokerage Practices, when requested to recommend a broker-dealer/custodian for client accounts, Marcum generally recommends that Schwab or Raymond James serve as the broker-dealer/custodian for client investment management assets. When client assets are managed on a non-wrap basis, broker-dealers such as Schwab and Raymond James may charge transaction fees for effecting certain securities transactions. In addition to Marcum’s investment advisory fee referenced in Fees and Compensation below, the client will also incur transaction fees to purchase securities for the client’s account (e.g., mutual funds and exchange traded funds purchased by Marcum for the client’s account, and individual equity and fixed income securities purchased by Marcum or any underlying Independent Manager). Account Aggregation Platforms Marcum, in conjunction with the services provided by ByAllAccounts, Inc., Pontera, Inc., Orion Advizr, and/or other third-party platforms, 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 Marcum (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not Marcum, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, Marcum’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if Marcum is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), Marcum does not maintain any trading authority for 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 Marcum were asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Marcum shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Marcum provide investment management services for the Excluded Assets, the client may engage Marcum to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Marcum and the client. Periods of Portfolio Inactivity Marcum has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Marcum 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, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Marcum determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Marcum will be profitable or equal any specific performance level(s). Client Obligations In performing our services, Marcum 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, it remains each client’s responsibility to promptly notify Marcum 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. 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 Marcum) will be profitable or equal any specific performance level(s). Wrap Fee Programs Marcum does not offer a wrap fee program for its investment advisory services. However, Marcum is a participating investment adviser in various unaffiliated wrap fee and managed account programs, including those sponsored by Raymond James & Associates, Inc., member New York Stock Exchange/SIPC, SEI Investment Management Corp., AssetMark, Inc., and Loring Ward (each a “Program Sponsor”). Under 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. Through the unaffiliated wrap fee program, the Program Sponsor also provides access to a managed account program, through which Marcum may allocate client assets to one or more unaffiliated discretionary investment managers. To the extent any such unaffiliated investment managers are utilized in the management of client accounts, the fees charged by the unaffiliated investment manager are separate from, and in addition to, those fees charged by Marcum for its investment advisory services. Annual fees charged by unaffiliated discretionary investment managers available through the program can range from 0.05% to 0.60% of client assets placed under management. Similar services may be available from other advisers or service providers for similar or lower fees. Ownership The Firm was founded in December 2006 and is owned by Marcum, LLP, Christopher Bart, James Butler, Steven Brett, Robert D. Coode, Robert E. Coode, Charles Hoffmann, Peter Hoffmann, Charles Moore, Perry Reghetti, Matthew Reghetti, Eric Wulff, Jeffrey Weiner, and Aurum Holdings, LLC. Marcum primarily provides advisory services to individuals, high net worth individuals, corporate retirement plans and other advisors. Assets Under Management As of February 9, 2023, Marcum manages approximately $2,221,195,330 on a discretionary basis and $29,632,857 on a non-discretionary basis. In addition, as of January 31, 2023, Marcum provides ongoing consulting to company-sponsored employee retirement plans in excess of $514 million.