Raymond James (USA) Ltd (“RJLU”) operates as an investment adviser registered with the Securities and Exchange Commission and as a full service broker-dealer registered with FINRA. Established in 1998, the firm is a wholly owned Canadian based subsidiary of Raymond James Ltd, which in turn is owned and operated by Raymond James Financial Inc. of St. Petersburg, Florida (Ticker symbol: RJF). RJLU may provide fee- based portfolio management services to individuals, corporate entities, trusts, high net worth clients, charitable organizations, pension/profit sharing plans, and institutional clients. As a registered investment adviser, the firm serves to actively manage a wide variety of investment portfolios. As part of the Raymond James family of companies, the firm maintains access to some of the industry’s finest resources which include brokerage, in depth market research services, an experienced management team, and a broad scope of service offerings. Generally, there are several fundamental differences between brokerage services and advisory services, which may vary depending on the characteristics of a particular service. Brokerage services primarily involve assisting the client with the purchase and sale of securities, with the provision of investment advice being only incidental to those services. Investment advisory services, on the other hand, primarily involve separately agreeing with the client to provide investment advice to meet comprehensive long-term financial goals. While providing advisory services, RJLU and its investment adviser representatives have a fiduciary duty to its advisory clients, must put the client’s interests ahead of its own, and must treat all of its advisory clients fairly and equitably. Asset management services (Ambassador) The firm provides asset management services on a discretionary and non-discretionary basis. As discussed in Item 16 of this wrap fee brochure, discretionary asset management means that the firm may act in the client’s interest by placing trades in the client’s account without first obtaining client approval for each transaction. The firm may not exercise discretion over a client’s assets without written authorization from the client. The Ambassador Account utilizes a wrap fee advisory account, offered and administered by Raymond James, in which the client is provided with ongoing investment advice and monitoring of securities holdings by their financial advisor. Raymond James acts as a participant as a sponsor and portfolio manager to the wrap fee program. The client’s financial advisor will supervise their account on a non-discretionary basis (or manage on a discretionary

basis, provided certain qualifications are met), according to the client’s objectives. Ambassador offers clients the ability to pay an asset-based advisory wrap fee in lieu of a commission for each investment transaction within the account. Ambassador-Directed The firm’s asset management services may include asset allocation recommendations to clients. The firm provides advice on asset allocation, diversification, and long-term investments as the primary strategies for pursuing investment objectives. Asset allocation entails the diversification of investments across various asset classes. The firm typically refrains from making any recommendations towards the short-term holding of investments. However, asset allocation and investment recommendations may cause the firm to recommend the sale of investments which have been held for less than one year in certain cases. In providing asset management services, RJLU will assist the client in completing suitability forms, including a client questionnaire, in order to determine the client’s investment objectives, needs, and risk tolerance. Based on information provided by the client, the firm will tailor its services to the individual needs of the client, using investment strategies discussed in Item 8 of this wrap fee brochure. In the management of client assets, the firm may invest, or recommend investment in, a wealth of investment products including, but not limited to, mutual funds, stocks, bonds, options, interests in limited partnerships and other investments. Clients may impose restrictions on investing in certain securities or types of securities. Third Party Platform - Envestnet RJLU may, when in the client’s interest, recommend that the client participate in the Private Wealth Management Program offered by Envestnet Asset Management, Inc. (“Envestnet”), a third party platform manager and investment adviser. Envestnet operates a technology platform on which the Private Wealth Management Program functions and renders investment advice, including recommending an appropriate asset allocation for the client and specific investment managers or investment products. In recommending the services of Envestnet, RJLU remains an investment adviser to the client and assists the client with program implementation, model and/or asset allocation selections, and provides continuous monitoring of the client’s account. The client grants RJLU and Envestnet discretion in this program. As of December 13, 2023, RJLU has approximately $1,300,000,000 in assets under management, of which $265,000,000 is discretionary.