A. Description of SCA; Ownership Structure Snowden Capital Advisors LLC (“SCA,” “we,” or the “Firm”), a Delaware limited liability company which was formed and began operating in 2011, is an investment adviser registered with the SEC. Such registration does not imply a certain level of skill or training. This Brochure is offered to potential and existing clients to provide an understanding of the services we provide and our conflicts of interest. The information in this Brochure has not been approved or verified by any governmental or regulatory authority. The advisory services described in this Brochure are not insured or otherwise protected by the U.S. government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other governmental agency and involve risk, including the possible loss of principal. SCA is wholly owned by SCP Intermediate Holdings LLC (“SCP Holdings”), a Delaware limited liability company. B. Description of SCA’s Advisory Services SCA provides fee-based discretionary and non-discretionary investment advice, consulting, and related wealth advisory services that are targeted primarily at high-net-worth clients, including family offices, individuals (and their investment vehicles), companies, foundations, governmental agencies, pension plans, and endowments, through experienced investment advisors and pension consultants (“Financial Advisors”). As requested by clients, SCA consultants may also provide financial planning services. Fees charged to clients vary depending upon the services provided by SCA. Clients select from a variety of investment management services, including portfolio management (implemented by SCA or an independent, third-party money manager), investment consulting, financial planning, and estate planning. SCA’s Financial Advisors may be specialists in areas such as wealth management, investment consulting, portfolio management, asset allocation, cash management, and/or financial and estate planning. Financial plans are not limited to products or services provided by any particular company; provided that, in general, only products and services that SCA is able to provide will be included in a financial plan. The terms of the advisory services that SCA provides for each client are set forth in the advisory agreement between SCA and such client (the “Advisory Agreement”). In some cases, a third-party manager or program sponsor may also be a party to the Advisory Agreement. Some platforms and programs also require an additional advisory agreement with clients in addition to the Advisory Agreement clients sign with SCA. Clients are able to impose restrictions on investing in certain securities or types of securities unless otherwise stated in the Advisory Agreement or a third-party advisory agreement. For all accounts, client assets are primarily custodied with Pershing LLC, member FINRA, NYSE, SIPC, a BNY Mellon company. Some accounts are held at another custodian as agreed to by SCA and client (each, as applicable, the “Custodian”). Other custodial platforms available include Charles Schwab & Co. (“Schwab”).1 The Custodian provides execution, clearance, and administrative services for clients. Clients whose assets are custodied with Pershing, LLC will enter into either (i) an account 1 We have recently initiated new custodial arrangements at Morningstar and AssetMark, where are assets are thus far de minimus. agreement with SAS, pursuant to which SAS will act as introducing broker for client’s account and introduce transactions in client’s account to Pershing, LLC for execution, clearance, and custody or (ii) an account agreement with Pershing Advisor Solutions LLC (“PAS” and together with SAS, the “Introducing Brokers” and each an “Introducing Broker”), Pershing, LLC’s affiliated introducing broker, pursuant to which PAS will act as introducing broker for client’s account and introduce transactions in client’s account to Pershing for execution, clearance, and custody. Clients with accounts held at Schwab will sign an account agreement with Schwab and with SCA. Schwab serves as the Introducing Broker for accounts custodied at Charles Schwab & Co. Many of SCA’s advisory services are offered as part of a “wrap fee” program, which is an investment program where clients pay SCA or a third-party sponsor an all-inclusive fee that covers investment management fees, trade execution, custodial services, and other administrative fees. SCA maintains a separate wrap fee program brochure on Appendix 1 to Form ADV Part 2A (“Wrap Fee Brochure”) that is provided to clients who open wrap fee accounts. 1. SCA Managed Account Programs SCA offers a program or programs in which clients grant SCA authority to manage their accounts on a discretionary basis in accordance with the client’s investment objectives, liquidity needs, risk tolerance, and investment time horizon, subject to any reasonable restrictions that the client has provided to SCA in writing and that SCA confirms it is able to implement. In these accounts, a client’s Financial Advisor is responsible for making investment decisions for the account as attorney in fact and discretionary adviser for the client. Each Financial Advisor typically manages his or her clients’ accounts utilizing a model developed by the Financial Advisor or a team of Financial Advisors that has been customized to the client’s individual investment style and strategy in accordance with each client’s description of its investment objectives, liquidity needs, risk tolerance, and investment time horizon. SCA’s managed account programs include the Discretionary Wealth Advisory Account Program (“DWA Program”). All Managed Account Programs are considered wrap programs, and all are offered on a discretionary basis except the Personal Wealth Advisory Program ("PWA"). The other Managed Account Programs are:
• Discretionary Wealth Advisory Program ("DWA")
• Brinker Capital Programs ("Brinker Programs")
• Independent Manager Portfolio Program ("IMP") administered by Envestnet Asset Management, Inc. ("Envestnet")
• PAS’ ManagedConnect (“ManagedConnect”)
• SCA Portfolios SCA's non-wrap and non-discretionary program is the Assets Held Away Program ("AHA"). These programs are described in more detail below. Wrap programs are described in more detail in the SCA Part 2A, Appendix 1 Wrap Fee Brochure ("Wrap Fee Brochure"). 2. Advice on Selecting Third-Party Investment Advisers and Programs Manager Selection SCA offers a program or programs in which SCA is engaged to provide advice to clients, on a non- discretionary basis, regarding the selection of third-party investment managers who, if suitable, will manage client accounts on a discretionary basis. These programs allow clients to obtain portfolio management services that typically have higher minimum account sizes off the platform or outside of the program. The third-party investment managers selected under these programs will have discretion to determine the securities they will buy and sell within the account(s), subject to restrictions imposed by the client. Each third-party investment manager maintains a separate disclosure brochure on Form ADV Part 2A (“Third-Party Brochure”), which will be provided to clients by their Financial Advisor. Clients should carefully review any Third-Party Brochure for important and specific details including, among other things, fees, experience, investment objectives and risk guidelines, and disclosure of the third-party investment manager's potential conflicts of interest. Depending upon the platform or program, SCA will:
• Assist clients in the identification of investment needs and objectives.
• Develop an investment policy and/or asset allocation strategy designed to meet the client’s objectives.
• Recommend specific investment styles and asset allocation strategies.
• Evaluate third-party investment managers and investment vehicles meeting style and allocation criteria.
• Negotiate fees to be paid to third-party investment managers.
• Assist in identification of appropriate third-party investment managers and investment vehicles suitable to the client’s goals.
• Perform ongoing monitoring and due diligence of individual third-party investment managers’ performance and management.
• Review the client’s account for adherence to objectives, policy guidelines, and/or asset allocation on a periodic basis.
• Recommend reallocation among third-party investment managers or styles within the program.
• Report to the client regarding the performance of their account. The nature of the services that will be performed by the third-party manager for each client are set forth in the manager’s Third-Party Brochure. SCA’s third-party

managed account programs currently include the Independent Manager Portfolio program (“IMP Program”) administered by Envestnet Asset Management, Inc. (“Envestnet”) Brinker Capital Program Selection SCA participates in an investment advisory program with Brinker Capital, Inc. (“Brinker”), a registered investment adviser, through which SCA may recommend, on a non-discretionary basis, programs sponsored by Brinker (the “Brinker Programs”) to its clients. SCA is responsible for initial and ongoing client contact and acts as a non-discretionary investment adviser in recommending the Brinker Programs. If a client selects one of the Brinker Programs, Brinker will act as a discretionary or non- discretionary investment adviser (depending upon the specific Brinker Program). With respect to both the IMP Program and the Brinker program, access to certain third-party investment managers, platforms, and programs may be limited to certain types of accounts and may be subject to account minimums, which will vary and may be negotiable depending upon the third-party investment managers, platforms, and programs selected. 3. SCA Non-Discretionary Programs SCA offers programs in which it provides investment advice to clients on a non-discretionary basis in accordance with the client’s investment objectives, liquidity needs, risk tolerance, and investment time horizon, subject to any reasonable restrictions that the client has provided to SCA in writing. In these accounts, the client’s Financial Advisor will recommend transactions for the purchase or sale of securities or other investments for the client’s account. Under the Personal Wealth Advisory Account Program (“PWA Program”), SCA will then arrange for execution of the purchase or sale of the securities or other investments for the client’s account only after the client requests that SCA arrange for a broker-dealer to effect the transaction. Under the Assets Held Away Advisory Program (“AHA Program”), clients are responsible for arranging execution of recommended transactions through their Custodian or another broker-dealer. AHA and PWA are the only non-discretionary management programs offered by SCA. Advice is provided to clients with accounts under the AHA program, but no trades are entered by SCA. AHA accounts are listed on quarterly performance reports and non-discretionary advice is provided to the client for them to implement if they choose to do so. 4. Financial Planning and Asset Allocation Services SCA offers general financial planning and asset allocation advice to clients. These services may be offered on a comprehensive or à la carte (limited focus) basis. Financial plans may encompass all or some of the following areas of financial concern to the client: estate planning goals; retirement planning; education planning; insurance planning; and risk management investments. To prepare a financial plan for a client, SCA will obtain appropriate information from the client through personal interviews or questionnaires (which include questions regarding client’s current financial status, future goals, attitude towards risk and other relevant information) and the review of related documents and data supplied by the client. A written financial plan may be prepared and provided. The implementation of financial plan recommendations is entirely at the discretion of the client. Financial plans are not limited in any way to products or services provided by any particular company. However, in general, only products and services that SCA can provide will be included and discussed in the plan prepared by SCA. 5. Consulting Services for ERISA Clients SCA provides the following services to clients who are subject to the Employee Retirement Income Security Act of 1974 (“ERISA”):
• Limited education and enrollment assistance.
• Draft, review, and refine the Investment Policy Statement (“IPS”) until the client (the plan sponsor and/or trustee) believes objectives and risk tolerances have been met.
• Work with the trustees of the plan to determine the appropriate mutual funds and/or securities for plan participant investments to meet the criteria outlined by the plan.
• Advise the trustees, on a non-discretionary basis, regarding the selection, supervision, and retention of external managers based on the plan’s investment policy and asset allocation.
• Meet with the trustees of the plan to review the performance of the mutual funds and other securities selected by the trustees. Make recommendations to the trustees, who then have the sole authority to determine the course of action to take on behalf of the plan.
• Provide periodic reports as agreed. When SCA provides consulting services for ERISA clients, it typically does not have control over plan assets or control over the administration of the plan. The consulting services provided are limited to those assets specifically identified in the Advisory Agreement. SCA may, on a case-by-case basis, choose to offer discretionary investment advisory services to select ERISA clients. C. Availability of Customized Services for Individual Clients Financial Advisors collect financial and additional relevant information from each client to identify the client’s investment objectives and financial situation. Financial Advisors provide ongoing investment advisory services to each client based on the services the client selected and the written information provided by each client to SCA regarding the client’s financial situation, investment objectives, risk tolerances, and investment experience, as well as other pertinent information. SCA clients may impose restrictions in writing on the management of their accounts. SCA reserves the right not to accept such restrictions or to terminate an account if SCA believes the restrictions imposed are not reasonable or prohibit effective management of the account by SCA. SCA is not obligated to implement any investment selections and will not do so if it believes such investments are inconsistent with a client’s risk tolerance or SCA’s management style. SCA will notify a client if it elects not to implement an investment selection made by the client. A client’s Financial Advisor uses written information provided by the client to identify an appropriate investment strategy and to comply with any client-imposed investment restrictions. Clients are responsible for updating all written information about their financial situation, risk tolerance, and investment goals periodically. SCA manages most clients’ advisory accounts with discretion. This allows SCA to determine the specific individual securities and other financial instruments to buy, hold, or sell without obtaining clients’ prior consent. SCA may also manage advisory accounts without discretion (non-discretionary accounts), meaning clients retain the authority to make investment decisions but SCA provides recommendations. Clients have an unrestricted right to decline to implement any advice issued on a non-discretionary basis. Based on clients’ needs, portfolios are designed and managed using a mix of investments, including stocks, bonds, mutual funds (stock funds, bond funds and other asset classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities and financial instruments as selected by SCA or third-party investment managers. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is most appropriate given the size of the client’s portfolio and the client’s investment goals and financial situation. Investments in mutual funds by a client will require payment of management fees to each mutual fund adviser in addition to the management fees that the client pays to SCA. In these situations, a portfolio of no-load or load-waived mutual funds will be created by SCA and client assets will be allocated among various mutual funds while taking into consideration the goals and objectives of the client and the appropriate overall management style of the funds. D. Portfolio Management Services to Wrap Fee Programs SCA provides portfolio management services to clients under the DWA Program, which is a wrap fee program that SCA sponsors. In general, SCA manages wrap fee accounts in a comparable manner to the other accounts that it manages. Under the DWA Program, SCA serves as the sponsor and portfolio manager and receives the full amount of the wrap fee charged to the client’s account. A portion of the wrap fee is attributable to the portfolio management services provided by SCA. E. Assets Under Management As of December 31, 2023, SCA had $5,932,368,220 in assets under management, $4,626,831,827 of which it managed on a discretionary basis and $1,305,536,393 of which it managed on a non- discretionary basis.