History FNFD is a dually registered broker-dealer and investment adviser. FNFD was formed as a broker-dealer in 1931, and has a history as an investment firm dating back to 1889. FNFD registered as an investment adviser in 2007 to participate as an investment adviser in wrap fee programs (all-inclusive fee that covers generally, advisory, brokerage, custodial and reporting services). Such wrap fee programs are currently made available by Pershing LLC (“Pershing”). FNFD is principally owned by several trusts of which members of the Folger family are beneficiaries. Current Advisory Business FNFD operates a limited private wealth management business that provides non-discretionary, fee- based investment advisory services (“PWM Business”) to a single ultra-high-net-worth family client (“PWM Client” or “Client”). This Brochure provides information on the PWM Business. The PWM Business currently provides advisory services to the PWM Client, through four accounts, each of which are principally owned by the PWM Client. The PWM Business is currently available only to the PWM Client and is not offered to any other clients. FNFD Account Executive(s) meet with the PWM Client to review the Client’s investment objectives, financial circumstances, risk tolerance, and investment profile information. This assessment is used to customize an investment management strategy consistent with client guidelines. The PWM Client has the ability to impose reasonable restrictions on the management of the account, in some cases including the designation of particular securities or types of securities that are permissible. The PWM Client will not be able to provide instructions that prohibit or restrict the investment adviser of an open-end or closed-end mutual fund or exchange traded funds with respect to the purchase or sale of specific securities or types of securities within the fund. The services provided typically include investment review, analysis, and recommendations combined with ongoing management for the PWM Client’s assets. Ongoing management, which occurs across key areas of the PWM Client’s personal

financial situation, generally includes, but is not limited to: (i) review and analysis of assets and debt positions; (ii) evaluating income and expense cash flow; (iii) optimizing estate and gift planning; and (iv) coordinating with the Client’s other professionals (e.g., accountants and attorneys). Customers’ Best Interest As a dually-registered investment adviser and broker-dealer, FNFD must act in the client’s best interest and not put the Firm’s interest ahead of yours. Where in the client’s best interest and where reasonable to do so, securities may be purchased in either a brokerage account with the transaction subject to a commission or transaction-based compensation, or in a fee-based advisory account. Within a fee-based advisory account, a client may either invest through (i) a wrap program that charges an annualized wrap fee (the wrap fee is an all-inclusive fee that covers generally, advisory, brokerage, custodial and reporting services); or (ii) a standard fee-based account that charges an annual advisory fee based on assets under management. When evaluating the account type for a retail customer, including the suitability of a wrap fee account, the Firm considers the following, as applicable:
• The investment profile of the retail customer;
• The types of services that are requested by the retail customer;
• The nature and extent of services and products provided in the account;
• Alternative account types that might be available; and
• The projected cost of providing the requested services to the retail customer of the account. The PWM Business is not offered to other clients, including clients who currently invest either through FNFD’s brokerage account option or wrap fee program. These programs, including an overview of how FNFD’s Account Executives evaluate which account type alternatives may be in the client’s best interest, are described in a separate Brochure (available from your Account Executive upon request). As of December 31, 2023, FNFD manages, on a non-discretionary basis, approximately $569,844,713 on behalf of the PWM Client.