A. Our Ownership and Structure Satovsky Asset Management, LLC (“SAM”, the “Adviser”, “we”, “us”, the “firm”, or “our”) is a New York City based wealth management firm. SAM is a limited liability company, organized in Delaware on March 5, 2007. Jonathan M. Satovsky is the Founder, Chief Executive Officer, and principal owner of the firm. Prior to starting SAM, Mr. Satovsky was a Senior Investment Adviser at Satovsky & Associates, a franchisee of Ameriprise Financial, Inc. (formerly American Express Financial Advisors, Inc.) since April 1994, during which time he provided financial planning and investment advisory services for individuals, pension and profit- sharing plans, trusts, estates, charitable organizations, and corporations. This background was the foundation for the continuation of these services for clients for which the Adviser serves. The Adviser provides holistic financial planning, wealth management, investment management and advisory services to separately managed accounts of high net worth individuals, trusts and estates, retirement plans, businesses and charitable organizations (collectively referred to as the “Client”, “Clients”, “Client Account” or “Client Accounts”) on both a discretionary and non-discretionary basis. B. Our Services Investment Management Services For discretionary accounts, SAM tailors its investment strategy in accordance with a specific Client’s investment objectives. We provide the Client with advice, guidance and implementation based on the structure of their balance sheet, cash flow and stated goals. Our process seeks to calibrate Client portfolios based on their need, capacity and willingness to take risk. This process requires ongoing collaboration and two-way communication (between the Client and SAM) to adjust to the Client changing circumstances. As a fiduciary, we seek out solutions with the aim of increasing both the probability of our Clients’ long-term success and the sustainability of their withdrawals from their portfolio. Client investment guidelines or Investment Policy Statements (“IPS”) may be amended by agreement with the Client and SAM, based upon changing market conditions or the needs of the Client. The portfolios may deviate significantly from stated IPS based on SAM discretion, market conditions and our proprietary research seeking to improve risk/return characteristics of the portfolios. We have a preference to create a passive structure and ideal path for each Client seeking to reduce taxes and behavioral risk. For non discretionary Client Accounts, the same process will occur as outlined above, except that Clients must approve the initial implementation and all subsequent changes to the asset allocation and trades. Within our non discretionary capacity, we may purchase or sell securities to meet the cash needs of the Client (including without limitation the payment of our management fee). These purchases and sales will be executed in a manner such that the resulting allocations will generally match the allocation and target range for asset classes in the account prior to the purchase or sale. Our advisory services are tailored to the objectives and strategies of each Client. On occasion, SAM will source, conduct due diligence, and recommend Clients to invest directly in third- party alternative investments. Clients must meet the criteria to invest in such funds and have ample liquidity to remain invested for a longer-term duration due to the potential liquidity constraints of such investments. SAM’s clientele is mostly taxable investors, and thus, ongoing efforts are made for optimal asset location, tax loss harvesting, trading and structure to balance the client’s lifetime goals and various forms of risk including longevity risk, inflation, taxes, volatility and client’s temperament which are all balancing factors in the decision-making processes. SAM allocates assets among various investment strategies, with a bias toward low-fee, tax advantaged investments typically embodied through a passive approach to markets. However, where certain inefficiencies present themselves or the Firm believes that a manager or strategy has an unusual advantage in a marketplace, SAM may suggest and employ other strategies. Where appropriate, these strategies include the use of independent investment manager(s), mutual funds, exchange-traded funds (“ETFs”), or other listed securities, in accordance with the investment objectives of its individual clients. Generally, outside scope of traditional risk profile, SAM may recommend investments in structured notes to clients that have excess cash reserves as a method to potentially increase yields for clients relative to their individual goals and circumstances. In addition, SAM may recommend that clients who are “accredited investors”, invest in privately placed securities, which may include debt, equity, and/or pooled investment vehicles. Where applicable, the Firm also provides advice about client-selected securities, legacy positions, or other investments held in client portfolios. Clients can engage SAM to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as but not limited to life insurance and annuity contracts and assets held in employer sponsored retirement plans, stock options, deferred compensation and qualified tuition plans (i.e., 529 plans). In these situations, SAM directs or recommends the allocation of client assets among the various investment options available within the product as well as seeking to align balance sheet and asset allocation taking these outside assets into consideration. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. SAM consults with clients on an initial and ongoing basis to recalibrate as needed. Clients are advised to promptly notify SAM if there are changes to their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if SAM determines, in its sole discretion, the conditions will not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Digital Wealth Management Platform SAM has partnered with Betterment for Advisors, a digital wealth management platform, through Betterment, LLC and Betterment Securities, (collectively referred to as “Betterment”). SAM may recommend this web-based electronic investment advisory program operated and provided by Betterment to provide services including but not limited to account opening, asset allocation, execution, rebalancing, daily tax-loss harvesting, asset location and financial projections, where applicable. Under this arrangement, clients must execute a separate discretionary investment advisory agreement with Betterment to serve as a sub-advisor. This online agreement provides access to Betterment’s

automated investment allocation platform as well as Betterment’s brokerage and custodial services which clients can access these accounts exclusively through Betterment’s website which outlines the terms, conditions and fees of the relationship. Clients provide Betterment with their financial circumstances and other information and their portfolio is created with asset allocations in exchange-traded funds (ETFs) that match tolerance levels of equity exposure relative to Client goals-based planning. Betterment then provides investment advice to the client and directs trades to its affiliate broker-dealer, Betterment Securities (neither client nor SAM can enter trades). Advice provided by Betterment is computer-generated, and therefore inherently has several limitations (including that neither SAM nor Betterment can ensure that the Program can achieve any particular investment or tax result for any client; the algorithm may rebalance Program accounts without regard to the then-current market conditions or on a more frequent basis than the client might otherwise expect the algorithm may not address prolonged market condition changes and the mathematical algorithms employed are designed properly, updates with new data and can accurately predict future security, market, industry, and sector performance); SAM will be unable to manage your Program account in a way we may otherwise advise for advisory accounts we manage; Betterment can amend the terms of the client’s agreement at any time; A client’s participation in the web-based electronic investment advisory program is subject to numerous conditions (as noted on the website); Clients must agree to arbitration of any disputes they may have with Betterment. SAM’s Digital Wealth Management offering seeks to align clients’ portfolios through a combination of ETFs to clients’ specific goals and therefore the risk profiling process seeks to consider age, time frame, equity exposure and rebalanced as tax-efficiently as possible seeking to minimize the Behavioral Gap over a lifetime, which is the difference between investment returns and investor returns due to behavioral biases. Institutional, Charitable and Retirement Plan Services We engage with various endowments, charitable gift trusts, and ERISA plans in a wide range of capacities. For ERISA plans, this includes serving as a 3(21) fiduciary providing investment recommendations to the plan sponsor and/or trustee, or as a 3(38) investment manager, relieving the plan sponsor or trustee of their fiduciary responsibility and assuming the investment management decision making for the plan. In addition, SAM has adopted policies and procedures designed to comply with the ERISA fiduciary standards when advising retirement asset rollovers as set forth in the Department of Labor Fiduciary Rule (‘’DOLE PTE”). Client will be presented with disclosure documents as prescribed by DOL PTE. Consulting, Financial Planning and Wealth Advisory Services SAM also is available for a fee to provide certain consulting services with respect to financial planning services as well as financial advice on non investment related matters such as but not limited to the following:  General financial oversight  Balance sheet and ongoing cash flow monitoring  Debt Management (Mortgages, Personal/Business Lines of Credit and Margin agreements)  Wealth Transfer and Estate Planning  Income Tax review and Planning  Insurance Review  Employee and Executive Benefits  Concentrated Equity and Business Ownership  Stock Options and Restricted Stock Awards  Pension and Annuity Evaluations  Philanthropy  Behavioral Coaching Under this arrangement, any recommendations provided by SAM may be implemented at the Client’s sole discretion with the professional consultants of Client’s choosing, and there is no obligation to engage SAM for investment advisory services. In performing these services, SAM is not required to verify any information received from the client or from the client’s other professionals (attorneys, accountants, and other advisors) and is expressly authorized to rely on such information. We also may provide certain Investment Only Client Accounts with financial planning services as well as financial advice on non investment related matters such as those listed above. To the extent we provide any financial consulting services beyond the management of assets, such services are provided as part of, and incidental to, our management services. With respect to any financial planning/consulting services provided by SAM, each Client must acknowledge to us that: (i) such Client is free at all times to accept or reject any of our recommendations, and such Client acknowledges that such Client has the sole authority with regard to the implementation, acceptance, or rejection of any recommendation or advice from us; (ii) our recommendations (i.e., estate planning, retirement planning, insurance, etc.) may be discussed and/or implemented, at such Client’s sole discretion, with the corresponding professional adviser(s) (i.e., broker, accountant, attorney, etc.) of such Client’s choosing; (iii) in respect to estate planning and tax planning matters, our role shall be that of a facilitator between such Client and his/her corresponding professional adviser(s); (iv) we are not an attorney or accountant, and no portion of our services should be interpreted by such Client as legal or tax advice (rather, such Client should defer to such Client’s attorney and/or accountant with respect to all legal or tax matters); and (v) such Client will maintain sole responsibility to notify us if there is a change in such Client’s financial situation or investment objective(s) for the purpose of reviewing/evaluating/revising our previous recommendations and/or services and/or to address new planning or consulting matters. SAM recommends the services of itself or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage SAM or Jonathan Satovsky as a registered representative to provide additional fee-based services (investment management, aggregate customized reporting, insurance/annuity solutions or special projects). Clients are advised that it remains their responsibility to notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising SAM’s previous recommendations and/or services. SAM does not sponsor nor provide portfolio management services to a wrap fee program. C. Regulatory Assets Under Management SAM provides investment management services on a discretionary and/or non‐discretionary basis to each of our Client Accounts. As of December 31, 2023, we provided investment management services to $792,106,127 of regulatory assets under management of which $776,546,594 is managed on a discretionary basis and $15,559,533 is managed on a non‐discretionary basis.