Advisory Business TPB Wealth Advisors, LLC (“TPB WEALTH ADVISORS” or “TPB Wealth”) (formerly Aspireon Wealth Advisors LLC) is a registered investment adviser with the United States Securities and Exchange Commission which began operations in 2009. TPB Wealth Advisors is a wholly owned subsidiary of Texas Partners Bank, LLC, which is a subsidiary of Southwest Bancshares, Inc. Southwest Bancshares, Inc. is a bank holding company. Texas Partners Bank, LLC does business as a bank under the following business names: (1) The Bank of San Antonio; (2) The Bank of Austin; and (3) Texas Hill Country Bank. Texas Partners Bank also wholly owns The Bank of San Antonio Insurance Group, along with TPB Wealth Advisors. These are our related companies. Further, TPB Wealth Advisors wholly owns two entities, which are discussed further throughout this brochure. TPB Opportunities Fund GP, Inc., is a Texas-based corporation, which serves as the General Partner to a series of private funds, TPB Opportunities Fund (formally named the Aspireon Opportunities Fund), and used by clients of TPB Wealth Advisors. TPB Investment Management, LLC., is a Delaware-based limited liability company, which acts as investment manager for day-to- day investment oversight of the TPB Opportunities Fund, LP series. Additionally, TPB Investment Management, LLC. operates as a relying advisor under TPB Wealth Advisors. TPB Wealth Advisors is a discretionary wealth management firm that provides comprehensive solutions, including financial planning and investment management. TPB Wealth Advisors seeks to serve the distinct needs of high-achieving clients who are committed to optimizing their financial resources as a means to fund their life’s purpose. Beyond driving investment results and managing risk on behalf of clients, TPB Wealth Advisors are committed to transparency and collaboration within a solutions-oriented framework that allows for custom access points, while engaging with clients on their terms. Financial Planning and Investment Advisory Services As part of its comprehensive services, TPB Wealth Advisors provides its clients with three primary solutions: (1) integrated financial planning, (2) investment advisory services, and (3) access to private pooled investment solutions. Services are offered based on a client’s financial situation and information shared by the client, depending on their goals and objectives. TPB Wealth Advisors may also refer clients to an accountant, attorney or other specialist, as appropriate for their unique situation. Financial Planning Solutions TPB Wealth seeks to provide each client with a summary of their financial situation, the advisors observations and recommendations, along with a plan of implementation supported by an investment program. While not every client will require or have similar financial planning needs, when possible TPB Wealth will seek to provide clients with the following: ▪ Development of comprehensive financial statements, including cash flow analysis and personal budgeting. ▪ Development of an income needs analysis showing the assets required to achieve the identified goals along with the probability of achieving those goals. ▪ Guidance and advice focused around retirement planning, education planning, estate planning, tax planning, legacy and philanthropic planning, etc. TPB Wealth Advisors does not provide legal or tax advice. ▪ Life, disability and other risk management insurance analysis and review. © TPB Wealth Advisors, LLC P a g e | 5 ▪ Business investment analysis, capital needs analysis and succession planning. Managed Investment Management Account(s) TPB Wealth Advisors looks to integrate the financial planning solutions with an investment program designed for each client, to address his/her financial goals, objectives and risk tolerance. As wealth advisors, we endeavor to consider the client’s complete financial outlook when making investment recommendations and planning for his/her short- and long-term goals. Therefore, we may structure our investment advice in view of any outside investments held by the client, taking into account each investment’s effect on the client’s risk budget and overall portfolio. A client engages TPB Wealth Advisors to provide investment advisory services on a fee basis determined by assets under management. TPB Wealth Advisors deliver its investment advisory services in a discretionary manner upon being engaged by the client. The client may impose reasonable restrictions on TPB Wealth with regards to implementation of the investment advisory services. Additionally, in limited instances, TPB Wealth Advisors may be engaged on a non-discretionary basis, at which point, TPB Wealth Advisors will provide reporting and assistance in any transactions at the direction of the client only, but will not monitor, review, recommend or advise the client or the clients investments. TPB Wealth Advisors has found that clients often have three broad goals: income generation and/or support; ongoing wealth accumulation; and opportunistic investments. These goals will vary for each client based upon their unique needs. Due to each goal being focused on a different purpose, they also present different risk to a client’s investment program. A client’s unique goals are used to determine the overall investment program and ensuing investment allocations in conjunction with the findings of the financial planning services. At the center of our investment program is a global, multi-asset class investment program which offers diversification using a number of investment processes. TPB Wealth Advisors feels that diversification achieved through using a number of distinct processes is stronger than diversification seeking different asset classes only. The investments in a client’s multi-asset class portfolio may include a wide spectrum of stocks, bonds, exchange traded funds (“ETF’s”), mutual funds, options, separately managed accounts (“SMA’s”), limited partnerships, such as hedge funds or private real estate, and independent managers representing a diverse number of distinct strategies. TPB Wealth Advisors will monitor the clients account(s) on an ongoing basis, make changes to the portfolios allocations as necessary, and communicate regularly throughout the year with its clients. All clients (in person or via telephone) are encouraged to review financial issues, investment objectives and account performance with TPB Wealth Advisors on an annual basis, if not more frequently. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the administrator/custodian and/or program sponsor for the client accounts. TPB Wealth Advisors Private Pooled Funds The TPB Opportunities Funds private Pooled Funds (“TPBOF Pooled Funds” or “Pooled Funds”) are unregistered funds of funds for which the firm or one of its subsidiaries serves as the general partner or managing member. The TPB Opportunities Fund LP is a Delaware-based multi-series limited partnership for which there are currently three underlying series: the TPB Opportunities Fund LP- Series 1 Open End Strategies (“TPBOE1”), the TPB Opportunities Fund LP- Series 2 Closed End Strategies (“TBPCE2”), and the TPB Opportunities Fund LP- Series 3 Open End Strategies II (“TPBOE3”). © TPB Wealth Advisors, LLC P a g e | 6 TPBOF Pooled Funds generally aggregate client capital for investment primarily in private funds managed by underlying managers or in direct (special purpose vehicles) private investments with underlying operators. The TPB Opportunities Fund seeks to offer clients access to investments focused on real asset-based strategies, namely across real estate and infrastructure related asset classes, while investing across debt and equity securities. The fund seeks to provide durable income buy owning long-lived assets, coupled with growth via the capital appreciation in its investments Additionally, TPB Wealth Advisors is the general partner and manager for SACM Biotech Ventures, LLC (“SACMBIO”), which was formed for the specific purpose of acquiring limited partnership interests in InCube Ventures II, L.P., a Delaware limited partnership. The manager (TPB Wealth Advisors), its principals and affiliates and family members reserve the right to purchase ownership interests in this entity. Less than 5% of TPB Wealth Advisors clients are invested in this Fund, which is not available to new investments. TPB Wealth Advisors, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to the Pooled Funds. TPB Wealth Advisors clients are under no obligation to consider or invest in any of the Pooled Fund, and not participating will not change the fees charged under the client’s investment management agreement. Upon the client agreeing to and subscribing in any of the Pooled Funds, TPB Wealth Advisors will on a go-forward basis exercise its discretionary authority when rebalancing the client’s investment accounts, and potentially increasing/decreasing the amounts invested to the Pooled Funds. The terms and conditions for participation in the Pooled Funds, including management fees, conflicts of interest, and risk factors, are set forth in each Pooled Fund’s offering documents. While TPBOF Pooled Funds generally charge a management fee of up to 1.50% of the limited partner’s capital commitment, capital contribution, or another measure of assets in the funds as applicable, the investment manager in order to avoid conflict of interest has established a no-management fee category. This category is reserved for any TPB Wealth Advisors advisory client, whereas the investment manager has agreed to waive the management fees related to the advisory client’s investment in the Pooled Funds. The Pooled Funds-related fees are described in detail in the offering materials of each Pooled Funds. Non- clients (external clients) who invest in TPBOF Pooled Funds pay the Pooled Funds’ management fees since they are not eligible for inclusion in a Pooled Funds no-management fee category or for a fee waiver. Should an investor in the Pooled Funds cease to be an TPB Wealth Advisors advisory client, then applicable management fees will be assessed. Since advisory clients and TPBOF Pooled Funds invest with underlying managers (i.e., in underlying funds, separate accounts/vehicles, and certain mutual funds/ETF’s), investors in the TPBOF Pooled Funds and advisory clients are also subject to the underlying managers’ management fees, incentive allocation, and other expenses, if any. The underlying managers generally charge a management fee of up to 2.0% of the limited partner’s capital commitment, capital contribution, or another measure of assets in the funds as applicable. In addition, the underlying managers generally receive an incentive allocation of up to 40% of an underlying fund’s or separate account’s returns. From time to time, TPB Wealth negotiates fee discounts or other rights for its clients with underlying managers which may be based on aggregate investments by firm clients. Both advisory clients and external investors in TPBOF Pooled Funds pay their proportionate share of the TPBOF Pooled Funds’ and, indirectly, the underlying funds’ expenses. Expenses borne by the TPBOF Pooled Funds and underlying funds include, but are not limited

to, costs and charges incurred, directly and indirectly, in connection with the formation, management, operation, maintenance and liquidation of the funds, which may include, among other fees and expenses, the following: legal expenses; accounting, tax, consulting and audit expenses; custodian and administration expenses; reasonable travel and other out of pocket expenses; costs associated with bookkeeping and reporting to investors; potentially compliance expenses of the fund, general partner and management company, as applicable; taxes, fees or other governmental charges; the cost of liability and other insurance premiums; litigation and indemnification costs and expenses; and other expenses not listed. Such expenses also include, but are not limited to, costs incurred in connection with the identification and investigation of potential © TPB Wealth Advisors, LLC P a g e | 7 investments (whether or not consummated) and the structuring, making, holding, tracking and disposing of investments, including professional fees, and, if applicable, commissions and other brokerage charges. Details regarding expenses can be found in the governing documents of the applicable TPBOF Pooled Fund. Miscellaneous Consulting Services To the extent requested by a client, TPB Wealth Advisors may determine to provide financial planning (including any of the services above or others) on a stand-alone separate fee basis. Prior to engaging TPB Wealth Advisors to provide financial planning or other consulting services on a stand-alone basis, clients are generally required to enter into a Financial Planning and Consulting Agreement with TPB Wealth Advisors setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to TPB Wealth Advisors commencing services. TPB Wealth Advisors offers consulting services including the review and evaluation of outside investments (e.g., self-directed 401K accounts offered by an employer), and non-investment related matters. Independent Managers TPB Wealth Advisors sources, evaluates and conducts due diligence on potential and existing underlying fund managers, tracks the performance of a range of sectors, strategies and markets, and identifies established underlying managers that we believe have a sound strategy, stable organization, and strong historical return characteristics as well as promising emerging firms. TPB Wealth Advisors 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. TPB Wealth Advisors shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. ByAllAccounts In conjunction with the services provided by ByAllAccounts, Inc., TPB Wealth Advisors 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 TPB Wealth Advisors (the “Held-Away Assets”). TPB Wealth Advisors service relative to these Assets is limited to reporting services only, which does not include investment implementation. Because TPB Wealth Advisors does not have trading authority for the Held-Away Assets, to the extent applicable to the nature of the Held- Away Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not TPB Wealth Advisors, shall be exclusively responsible for directly implementing any recommendations relative to the Held-Away Assets. Rather, the client and/or his/her/its other advisors that maintain trading authority, and not TPB Wealth Advisors, shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, TPB Wealth Advisors shall not be responsible for any implementation error (timing, trading, etc.) relative to the Held-Away Assets. In the event the client desires that TPB Wealth Advisors provide investment management services (whereby TPB Wealth Advisors would have trading authority) with respect to the Held-Away Assets, the client may engage TPB Wealth Advisors to do so pursuant to the terms and conditions of the Investment Management Agreement between TPB Wealth Advisors and the client. © TPB Wealth Advisors, LLC P a g e | 8 Envestnet-Tamarac Client Portal TPB Wealth Advisors may provide its clients with access to an online platform hosted by Envestnet-Tamarac, Inc. The Tamarac platform allows a client to view his/ her/its complete asset allocation, including Held-Away Assets. TPB Wealth Advisors does not provide investment management, monitoring, or implementation services for the Held-Away Assets. Therefore, TPB Wealth Advisors shall not be responsible for the investment performance of the Held-Away Assets. Rather, the client and/or his/her/its advisor(s) that maintain management authority for the Held-Away Assets, and not TPB Wealth Advisors, shall be exclusively responsible for such investment performance. The client may choose to engage TPB Wealth Advisors to manage some or all of the Held-Away Assets pursuant to the terms and conditions of an Investment Management Agreement between TPB Wealth Advisors and the client. Money Guide Pro Client Portal TPB Wealth Advisors may provide its clients with access to an online platform hosted by “Money Guide Pro” (MGP). The MGP platform allows a client to view his/her/its complete asset allocation, including Held-Away Assets. TPB Wealth Advisors does not provide investment management, monitoring, or implementation services for Held-Away Assets. Therefore, TPB Wealth Advisors shall not be responsible for the investment performance of the Held-Away Assets. Rather, the client and /or his/her/its advisor(s) that maintain management authority for the Held-Away Assets, and not TPB Wealth Advisors, shall be exclusively responsible for such investment performance. The client may choose to engage TPB Wealth Advisors to manage some or all of the Held-Away Assets pursuant to the terms and conditions of an Investment Management Agreement between TPB Wealth Advisors and the client. The MGP Platform also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by TPB Wealth Advisors. Finally, TPB Wealth Advisors shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the MGP platform without TPB Wealth Advisors’ assistance or oversight. Non-Discretionary and Reporting Only Accounts For the convenience of certain clients, TPB Wealth Advisors may offer either non-discretionary investment accounts or accounts for which TPB Wealth Advisors provides limited reporting services only. TPB Wealth Advisors does not provide investment management or monitoring services for the non-discretionary accounts. TPB Wealth Advisors does not provide investment management, monitoring, or implementation for reporting only assets. Therefore, TPB Wealth Advisors shall not be responsible for the investment performance of the assets. Rather, the client and/or his/her/its advisor(s) that maintain management authority for the assets, and not TPB Wealth Advisors, shall be exclusively responsible for such investment performance. Cash Positions At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), TPB Wealth Advisors may maintain cash positions for defensive or other purposes. All cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating TPB Wealth Advisors advisory fee. These cash positions may cause the clients investment goals to not be fulfilled. Retirement Plan Rollovers-No Obligation/Conflict of Interest A client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in his/her former employer’s plan, if permitted, (ii) roll over the assets to his/her new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or © TPB Wealth Advisors, LLC P a g e | 9 (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). TPB Wealth Advisors may recommend an investor roll over plan assets to an IRA managed by TPB Wealth Advisors. As a result, TPB Wealth Advisors and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave his/her plan assets with his/her former employer or roll the assets to a plan sponsored by a new employer will generally result in no compensation to TPB Wealth Advisors (unless the client engages TPB Wealth Advisors to monitor and/or manage the account while maintained at the client’s employer). TPB Wealth Advisors has an economic incentive to encourage a client to roll plan assets into an IRA that TPB Wealth Advisors will manage or to engage TPB Wealth Advisors to monitor and/or manage the account while maintained at the client’s employer. There are various factors that TPB Wealth Advisors may consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus TPB Wealth Advisors, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. No client is under any obligation to roll over plan assets to an IRA managed by TPB Wealth Advisors or to engage TPB Wealth Advisors to monitor and/or manage the account while maintained at the client’s employer. Client Obligations In performing its services, TPB Wealth Advisors 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, each client is advised that it remains his/her/its responsibility to promptly notify TPB Wealth Advisors if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising TPB Wealth Advisors previous recommendations and/or services. Clients Assets Under Management As of December 31, 2022, TPB Wealth Advisors had $844,792,764 in assets under management, of which $ 815,530,186 were discretionary assets under management, and $29,262,578 were non-discretionary assets under management.