CPA is a Delaware limited liability company formed in March 2021. On May 31, 2021, CPA succeeded to the investment advisory business of Cowen Prime Advisors, which was previously operating as a division of Cowen Prime Services LLC (“CPS”) under the name, Cowen Prime Advisors. There were no practical changes of control or management of CPA and it operates as a separate firm and as an affiliate under common control with Cowen and Company, LLC (“CCO”), a Delaware limited liability company. CPA is directly owned by Cowen PB Holdings, LLC, a Delaware limited liability company, which in turn is primarily owned by Cowen Inc., a Delaware corporation. CCO serves as a broker-dealer for the execution of transactions in CPA client accounts. In November 2022, Cowen shareholders approved an agreement for Cowen, Inc. to be acquired by The Toronto-Dominion Bank in an all-cash transaction valued at approximately $1.3 billion. The transaction was closed on March 1, 2023. As a result, Cowen, Inc. is a wholly owned, indirect subsidiary of The Toronto-Dominion Bank. CPA offers several investment advisory services to its clients, many of which provide differing types of investment management styles and/or services. This Brochure relates only to the ISV Program, and no other advisory programs are discussed in this Brochure. Information regarding other investment advisory programs offered by CPA is contained in other CPA brochures which may be obtained by contacting CPA at the address and phone number referenced above, Attn: Rep Poppell, Chief Compliance Officer. The ISV Program

focuses on the discretionary management of client funds pursuant to an investment strategy that seeks enhanced absolute and relative returns while seeking to minimize risk to capital over a five-year investment horizon. The ISV Program utilizes a value-oriented approach to investment selection focusing on investments as to which it is believed the intrinsic value will increase over time, and it does not limit itself to investments in particular market capitalizations, industry classifications or security type. See the discussion in Item 8 below for a description of the methods of analysis and investment strategies used in the ISV Program. Since this Program tends to invest on a highly concentrated basis (defined by the number of investments) in a wide range of securities with varying market capitalizations, industry classifications and security types, it is generally not possible to tailor portfolios to the particular needs of any particular client. This program will adjust the degree of concentration and diversification depending on risk tolerance, investment goals of the client and market conditions. Generally, the number of equity securities positions held per account is less than fifty. In addition, a client would not normally have the ability to impose any restrictions on investing in certain securities or types of securities within the ISV Program. As of the December 31, 2022, CPA managed approximately $345,388,040 of client assets on a discretionary basis. Of this amount, approximately $138,502,863 was managed as part of the ISV Program.