Description of Hightower Hightower, a Delaware limited liability company, was established in September 2008. The firm is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act” or the “Rule”). Hightower is a wholly owned subsidiary of Hightower Holding, LLC, whose parent company is majority owned by private investment funds managed by Thomas H. Lee Partners, L.P. and certain related fund investors (the “THL Entities”). Hightower and some of its Supervised Persons (as defined in the Advisers Act) also own interests in Hightower Holding, LLC, but no individual or entity owns more than 25% of the interests in Hightower directly or indirectly, except for the THL Entities. Hightower provides investment advisory services to individuals and institutions, including pension plans and other plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) as further described in Item 7. These advisory services are provided through its network (the “Advisor Practices”) of Investment Adviser Representatives (“Advisor(s)” or “IAR(s)”), each of which has its own advisory focus and strategies driven primarily by the types of clients they service and their expertise. The individual office locations for Hightower’s Advisor Practices are listed on Schedule D of Hightower’s Form ADV Part 1 (available at https://adviserinfo.sec.gov/). Certain Advisor Practices use branding and marketing specific to their practice – their affiliation and relationship with Hightower is further described in their Form ADV Part 2B Supplements. Advisory Services Offered by Hightower Hightower offers investment advisory services through its Advisor Practices on a discretionary or non-discretionary basis. Additionally, Hightower offers other services to retail investors, such as financial planning, for a fixed or hourly fee. When a new client opens an advisory account with Hightower, an Advisor will meet with them to discuss their investment goals and collaborate with them to design an investment strategy for their portfolio, which may include recommendations of stocks, bonds, mutual funds, options, warrants, real estate investment trusts, exchange traded funds (“ETF”s), alternative investments and other securities. Hightower’s management of the client’s account is guided by their investment objectives (e.g., capital appreciation, growth, income, or growth and income), risk tolerance and tax considerations. Hightower and the Advisor conduct ongoing monitoring of the client’s advisory account tailored to their advisory relationship and type of account. The Advisor will contact the client at least annually to discuss their portfolio. In most cases, clients may place reasonable restrictions on the types of investments that will be made on their behalf. Hightower reserves the right to decline such restrictions or to terminate the account if Hightower believes the restrictions imposed are not reasonable or prohibit effective management of the account. Discretionary Advisory Services Hightower predominantly furnishes investment advice through discretionary advisory services. Discretionary advisory services begin upon the completion of a financial assessment of the client and memorialization of the appropriate investment objectives (e.g., suitability profile form). Each discretionary advisory client grants investment discretion to Hightower to manage the client’s assets in accordance with his or her investment objectives and pursuant to a Discretionary Client Advisory Agreement. The client’s Advisor designs and continuously manages a portfolio of appropriate investments. Non-Discretionary and /or Investment Consulting Services Some Advisor Practices offer non-discretionary investment advisory services, as well. The predominant difference between the discretionary services described above is obtaining client consent prior to executing any trade or transaction fulfilling the Advisor’s recommendation. In an investment consultant relationship, the Advisor will use information provided by the client to identify an appropriate investment strategy. The Advisor will provide investment recommendations to the client, either in terms of the asset class or specific type of security, in each case based upon the identified strategy. The Advisor will otherwise consult with and advise the client regarding their investments and will provide ancillary services that are of limited scope. Investment consulting clients do not grant Hightower investment discretion, which means that the client makes the ultimate decision regarding the purchase or sale of investments. Hightower Investment Solutions Hightower’s Investment Solutions group (“Investment Solutions” and included within the definition of “Affiliated Manager” below) is a team of investment professionals within Hightower led by Hightower’s Chief Investment Strategist and Portfolio Manager. Investment Solutions offers the capabilities and resources of an institutional asset manager to Advisors and their clients, including customized portfolio construction and investment due diligence expertise. An Advisor may access Investment Solutions’ capabilities for its clients. The Advisor can allocate all or a portion of a client’s assets to Investment Solutions to manage according to one or more equity, fixed income or multi- asset portfolios selected by the Advisor, based on the Advisor’s assessment of its client’s needs. Investment Solutions constructs and manages each of these portfolios based on its proprietary fundamental and quantitative analysis, internal and third-party research and industry experience. For certain multi-asset portfolios that employ a strategic asset allocation strategy, Investment Solutions seeks to achieve the portfolio’s objectives by investing in mutual funds, ETFs, alternative investments and separately managed accounts managed by third-party investment advisers (see “Managers” below). A client may pay an additional fee to Hightower on the portion of its account assets that are allocated to Investment Solutions (see also Item 5). This additional fee presents a conflict of interest for Hightower and the Advisors as discussed in this Item. Managers In addition to the Advisor who manages a client’s account, a client may access other investment managers (“Managers”) who offer specialized asset management expertise or services to manage all or a portion of the client’s assets in appropriate cases. These Managers may include: (1) unaffiliated third party managers (each, a “Third Party Manager”) available through a custodian, broker-dealer or other platform, or (2) portfolio management strategy team within Hightower or its affiliates (each, an “Affiliated Manager” and together with Third Party Manager a “Manager”). A Manager’s particular expertise may include specialized research, selection of investment options, monitoring of account assets, trading decisions, tax mitigation techniques and other benefits. Once selected, a Manager has discretion, with respect to the portion of the client’s assets allocated to it, allowing the Manager to choose and prudently manage investments for the client. In exercising this discretion, a Manager will generally develop an appropriate investment strategy, buying and selling securities in accordance with that strategy, subject to restrictions imposed by the client. In some cases, a client may be able to access a Manager through an allocation of its Hightower advisory account when the client would not otherwise be able to do so directly due to a relatively high minimum account size imposed by the Manager. The Advisor has no ability to affect the trading decisions of a Third Party Manager once a client’s assets are allocated to such Manager and can only choose whether to engage or terminate a Manager or to change the allocation of assets to such Manager. If a client has provided Hightower with discretionary authority, the client’s Advisor has the ability to hire and fire a Manager on behalf of the client without further approval from the client (including the ability to replace any existing Third Party Manager with another or with an Affiliated Manager and vice versa). Hightower, or a third party that makes Managers available to Hightower, may limit the universe of Managers available to any Advisor and its clients or change such availability in their discretion. The client’s Advisor will evaluate the Manager and investment vehicles to determine whether the Manager is suitable for the client, given the Manager’s style and allocation. Clients should carefully review Manager disclosure documents for important and specific details including, among other things, fees, experience, investment objectives and risk guidelines, and disclosure of the potential conflicts of interest. A client may pay an additional fee on assets in a client’s account that are allocated to a Manager (see Item 5). The ability to earn fees for an Affiliated Manager, and, for certain fee structures, Advisors’ ability to retain a greater portion of certain fees by choosing an Affiliated Manager, provide direct and indirect financial incentives for Hightower and/or the Advisor to allocate the client’s assets to one or more Affiliated Managers, which they would not otherwise earn if the Advisor managed the assets him- or herself or allocated those assets to a Third Party Manager, and thus present conflicts of interest for Hightower and the Advisors. Hightower and its Advisors are subject to policies and procedures designed to identify and appropriately manage these conflicts of interest consistent with our duties to our clients. Schwab Institutional Intelligent Portfolios On a limited, case-by-case basis, Hightower utilizes an automated investment program (the “Program”) as a tool for smaller accounts. This Program can enable Hightower to be more efficient in executing portfolio changes over time through which clients are invested in a range of investment strategies the firm has constructed and also manages, each consisting of a portfolio of exchange-traded funds and mutual funds (“Funds”) and a cash

allocation. In essence, Hightower has created a hybrid solution for smaller accounts that offer the same level of portfolio management and oversight as much larger relationships. Program clients are given the same portfolio performance reporting as similar clients under the same service matrix and expertise, regardless of whether they are using the Program. This is an active portfolio rather than a passive allocation. Clients may instruct Hightower to exclude up to three Funds from their portfolio enrolled in the Program. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). Hightower uses 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. Hightower is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). Hightower, and not Schwab, is the client’s Advisor and primary point of contact with respect to the Program. Hightower is 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. Hightower has contracted with SPT to provide the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables Hightower to make the Program available to clients online and includes a system that automates certain key parts of Hightower’s investment process (the “System”). The System includes an online questionnaire that can help Hightower determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. In other cases, Hightower may recommend a portfolio via the System based on information the client provides to Hightower. Clients should note that, if Hightower uses the online questionnaire, Hightower 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 Hightower manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). Hightower charges clients a fee for its services (see Item 5) as the client’s Advisor. Hightower’s fee is not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, SSB, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that Hightower selects to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab receives from the market centers where it routes ETF trade orders for execution. Financial Planning Hightower also offers financial planning services on a comprehensive or discrete basis. Generally, this process seeks information about the client’s current assets, liabilities, income sources and expenditures, current tax status and future objectives, educational, retirement and other long-term financial goals, insurance and estate planning needs. Hightower relies on the client’s care, completeness and clarity in responding to the Advisor’s information request, as the client’s input will form the factual basis for the financial plan. Each financial plan is tailored to the individual needs of the client, but generally the financial plan shall include an analysis of the client’s current financial position, a summary of the client’s financial objectives that were identified in the discovery process, recommendations and an analysis regarding each of those financial objectives. Retirement Plan Services With respect to Hightower’s Retirement Plan services, Advisors assist clients that are trustees or other fiduciaries to retirement plans by providing fee-based consulting and/or advisory services. Such retirement plans may be subject to ERISA. Advisors perform one or more of the following services summarized below, as selected by the client in the client agreement. Investment Advisory Services
• Assist the retirement plan sponsor client in the preparation or review of an Investment Policy Statement (IPS) for the retirement plan.
• Recommend or select specific investments to be held by the retirement plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the retirement plan.
• Perform ongoing monitoring of investment options available in the retirement plan.
• Provide assistance in identifying an investment product or model portfolio in connection with the definition of a Qualified Default Investment Alternative under ERISA.
• Develop asset allocation target-date or risk-based model portfolios for the retirement plan to make available to retirement plan participants, based on funds from the line-up of investment options chosen by the client, and to periodically review these with the client during retirement plan reviews at such frequency as is mutually agreed upon.
• Prepare reports outlining the performance of retirement plan investment options. Plan Consulting Services
• Assist the retirement plan sponsor client by acting as a liaison between the retirement plan and service providers, product sponsors and/or vendors.
• Provide education, training and/or guidance for the members of the retirement plan committee with regard to plan features, retirement readiness matters or service on such committee.
• Assist the client in enrolling participants in the retirement plan, including providing participants with information about the retirement plan.
• Assist with participant education, which may include preparation of education materials and/or conducting investment education seminars and meetings for retirement plan participants.
• Assist with the preparation, distribution and evaluation of request for proposals, finalist interviews and conversion support.
• Provide the client with comparisons of retirement plan data (e.g., regarding fees and services and participant enrollment and contributions).
• Assist client in identifying the fees and other costs borne by the retirement plan. Hightower provides these services as an investment adviser and fiduciary under the Advisers Act. If a client elects to engage Hightower and its Advisors to perform ongoing investment monitoring and ongoing investment recommendation services to a retirement plan subject to ERISA, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Depending upon the scope of services offered by the Advisor, a client may also have the option of engaging Hightower and the Advisor to provide certain of the above Investment Advisory Services on a discretionary basis as an “investment manager” under Section 3(38) of ERISA. Therefore, Hightower and the Advisor will be deemed a “fiduciary” as such term is defined under ERISA when providing either non- discretionary investment advice or discretionary investment manager services, as designated in the client account agreement. Clients should understand that to the extent Hightower and an Advisor are engaged to perform services other than ongoing investment monitoring and recommendations (e.g., investment education and general financial information), those services are not “investment advice” under ERISA and therefore, Hightower and the Advisor will not be a “fiduciary” under ERISA with respect to those other services. Private Funds Managed by Hightower Hightower and its affiliates provides investment management services to a limited number of private investment funds. Hightower generally allocates the Fund’s capital in private investment vehicles managed by third-party investment managers (“Underlying Fund Managers”). Such Underlying Fund Managers may invest or trade in a wide variety of securities and financial instruments, domestic and foreign, whether publicly traded or privately placed. Hightower may provide discretionary investment advisory services to other private investment funds in the future. Wrap Program Hightower also offers its discretionary investment advisory services through a wrap fee program (the “Advisor Directed Program”). Hightower does not manage discretionary advisory accounts differently based on whether they are wrap accounts or non-wrap accounts. Rather, the decisions are driven by the client’s preferences, best interest and strategies utilized. A client should discuss with its Advisor whether a wrap fee program would be appropriate for the client based on the following factors, among others: (i) the asset class and types of investments the client will invest in, as well as the fee/expense levels associated with such assets, (ii) the extent of the anticipated trading activity in the account, and (iii) the client’s overall preferences in establishing a consolidated investment program and other factors. Hightower receives a portion of the wrap fee for its services. For more information on the Advisor Directed Program please refer to Hightower’s wrap program brochure Form ADV Part 2A, Appendix 1. Assets Under Management As of December 31, 2023, Hightower had $122,850,556,340 in assets under management that are managed on a discretionary basis and $7,388,781,034 in assets under management that are managed on a non-discretionary basis.