Oxbow Advisors, LLC is a limited liability company incorporated under the laws of the State of Texas and has been a registered investment adviser with the U.S. Securities and Exchange Commission since June 2011. Registration does not imply any certain skill or training. Prior to 2011 the Firm was named Herndon Plant Oakley Advisors. This was an ownership change only and does not reflect a change in investment personnel, investment policy or strategy at the firm. Oxbow’s principal owner and founder is James Theodore “Ted” Oakley. Chance Finucane has a 9% ownership in the Firm. All personnel of the Firm are expected to have education and business backgrounds that enable them to perform their respective responsibilities effectively. In assigning responsibilities, we consider academic background (including studies in college and graduate schools, as well as degrees earned), industry training, licenses and certifications. Work experience in a related field, such as investments, commodities, insurance, banking or accounting, is also considered. No formal, specific standards have been set, but appropriate education and experience are required. See the Form ADV, Part 2B Brochure Supplement for additional information. As of December 31, 2023, the Firm had $1,948,085,898 in client assets under management, all managed on a discretionary basis. Types of Advisory Services and Investments Oxbow Advisors is an investment advisory firm providing investment advice and discretionary supervisory portfolio management services to securities portfolios on a continuing basis, including the strategic allocation of managed assets among cash, stocks, and bonds with the selection of specific securities designed to provide proper diversification and help meet the client's stated investment objectives. In effecting such services, we advise directly and/or invest clients' funds through other investment advisors and/or third-party money managers. Discretionary clients can impose reasonable restrictions on the Firm’s authority to invest the client’s assets in certain types of investments. Oxbow utilizes the following as well as the foreign equivalents of the following investment products:
• Equity securities (exchange-listed, over the counter, foreign issuers)
• Warrants
• Corporate debt securities
• Commercial paper
• Certificates of deposits
• Municipal securities
• Mutual funds and exchange-traded funds
• United States government and government-agency securities
• Option contracts on securities Oxbow clients include those with whom Oxbow has a direct contractual relationship through Oxbow Advisors, LLC Discretionary Investment Advisory Agreement, those who have enrolled in asset-based wrap fee programs sponsored by an unaffiliated dual-registrant broker- dealer/investment adviser, and clients where Oxbow acts as a sub-adviser. Oxbow offers the following advisory services:
• Financial planning services
• Portfolio management services for individuals and/or small businesses
• Portfolio management for businesses or institutional clients (other than registered investment companies and other pooled investment vehicles)
• Pension consulting services
• Selection of other advisers
• Corporate Retirement Planning
• Individual Consultation
• Publication of Periodicals
• Educational seminars/workshops
• Sub-Advisory Services Separate Accounts Oxbow advisory services to separately managed accounts are customized based on each separate account client’s expectation, tolerance for risk, tax situation, volatility, and the need for liquidity. During initial and on-going discussions with each client, Oxbow develops the personal investment profile that includes specific client information and a general profile of the client’s risk tolerance, recommended investment strategy, income requirements, distribution requirements and any account restrictions. As mentioned previously, clients can direct specific investments that may not be in the Oxbow strategy and therefore are not followed by Oxbow’s team of portfolio managers and investment committee. Retirement Accounts When we make rollover recommendations to manage your retirement account (including IRA, HSA and ESA), we are fiduciaries under Title I of the Employee Retirement Income Security Act (“ERISA”) and the Internal Revenue Code (“IRC”), which are laws governing retirement accounts. As such, we operate under a special standard of care to provide prudent advice requiring us to act in your best interest and not put our interests ahead of yours, charge no more than a “reasonable fee”, as defined under ERISA, and not make any false or misleading statements about conflicts, fees and investments. We are required to give you basic information about our conflicts of interests, such as in the way we make money. When we make rollover recommendations this allows us to earn an additional fee that is in our interest. To address these conflicts,

we follow policies and procedures designed to reasonably ensure that we give advice that is in your best interest. (See Item 10 for other conflicts of interests) Wrap Fee Programs Oxbow Advisors acts as a portfolio manager for several wrap fee programs in which the client pays one fee to the wrap program sponsor for all services associated with the management and execution of transactions in their account. Oxbow does not sponsor any wrap fee program. Oxbow does not have the primary responsibility for maintaining on-going relations with the clients within the wrap program. Oxbow receives a portion of the total wrap fee paid to the wrap program sponsor for its portfolio management services. Oxbow does not solicit these clients but will provide client statements if requested. Although strategies vary and clients can impose guidelines that result in the way we manage their accounts, there is fundamentally no difference between how we manage wrap and non-wrap clients’ accounts. Sub-Advisory Services The Firm from time to time utilizes unaffiliated money managers or investment advisors as part of the client’s overall investment strategy. Through this arrangement, the client authorizes the Firm to hire, retain and/or terminate subadvisors authorizing them to invest those assets according to the stated investment strategy. In consideration for such, the third-party money manager/advisor will receive a portion of the management fee that Oxbow receives from the client’s portfolio. As part of this service, the Firm will perform third-party money manager/advisor due diligence, which includes research, recommendations, monitoring, and quarterly consolidated performance reporting. Financial Planning The Firm provides financial planning services to its existing clients and prospects at no additional charge. The financial planning services provided can include retirement planning and analysis, investment management and education planning, and other specialty services. Under a full-management (discretionary) agreement, the Firm is granted authority to place orders to execute transactions on the client’s behalf with FINRA member firm brokers, in accordance with the client’s asset allocation guidelines. The services are based on information that is provided to us by the client or prospective client. This information includes, but is not limited to, the client’s financial objectives, risk tolerance, financial resources, family situation and future financial goals. Documents requested by Oxbow to develop the plan could include tax returns, financial statements, bank statements, list of investments, insurance policies, etc. It is important that the information provided to Oxbow is accurate and complete. Oxbow is not responsible for verifying the accuracy of the information provided by the client or prospective client. Sub-Adviser to a Registered Investment Adviser Oxbow Advisors is an investment sub-adviser to Private Advisor Group, LLC (“PAG”). The sub-advisory services provided by Oxbow include using one or more of Oxbow’s investment strategies. PAG provides Oxbow with the desired portfolio strategy for a Client’s Assets prior to Oxbow management. Oxbow’s investment services shall be limited to the management of Strategies with respect to Client’s Assets and will not include any financial planning on behalf of the client. Private Advisor Group, LLC is not affiliated with Oxbow Advisors, LLC and the management of the accounts and trading activity is solely at the discretion of Oxbow and subject to the investment sub-adviser agreement between Oxbow and PAG. Corporate Retirement Planning The Firm provides one or more of the following services for corporate retirement plans: (1) create an Investment Policy Statement to document the plan goals, investment selection process, ongoing monitoring, and employee communication; (2) select investment options based on appropriate due diligence, not revenue sharing with a third party; (3) design a plan consistent with the plan’s objective of implementing appropriate investment strategies (asset allocation); (4) offer guidance on company stock as a plan option; (5) act as the prudent advisor to the plan committee; (6) assist the plan sponsor with avoiding conflicts of interest; and (7) review plan expenses. The Firm also provides advisory and consulting services to businesses for corporate retirement plans. The Firm acts as a third-party independent advisor over existing relationships with current plan providers or may recommend the replacement of existing providers. The Firm does not act as the plan sponsor or administrator but can identify firms that offer such services. Individual Consultation The Firm will consult with individuals or institutional clients on a single-project or ongoing basis to advise them regarding general economic and investment matters or specific investment programs. Fees for such services are on an hourly basis, currently at a rate of no more than $500 per hour. Fees for these services may also be charged at a fixed rate of no more than $5,000 annually.