A. Isthmus Partners, LLC Isthmus Partners, LLC (“Isthmus Partners” and/or “the firm”), is a Wisconsin limited liability company and an SEC-registered investment adviser. The firm is owned by Frank J Gambino, David A Hackworthy, Joel C McNeil, Victor E Rodriguez, and Jeremy Baier. The firm has been providing investment advisory services since 2014. A.1. Advisory Services Offered The investment advisory services offered by Isthmus Partners include portfolio management, investment advice, performance reporting, and related account services. The firm may also offer financial planning services to certain clients. Isthmus Partners offers three primary investment strategies to individual clients: (1) a Large Cap Core Equity Counseled Portfolio; (2) a Small-Mid Cap Core Equity Counseled Portfolio; and (3) a Small Cap Core Equity Counseled Portfolio (the “Counseled Portfolios”). Isthmus Partners may also offer certain Counseled Portfolio clients fixed income portfolios, international equity portfolios, or portfolio of mutual fund portfolios. Fixed income, international equity portfolios, and portfolio of mutual fund portfolios are only available to Counseled Portfolio clients as part of a larger diversified portfolio. Isthmus Partners typically provides Counseled Portfolio clients with advice and guidance on matters including, but not limited to, asset allocation and financial planning, along with discretionary investment management over the client’s account. The firm seeks to meet the client’s particular investment needs by developing a customized investment strategy based upon guidelines that are jointly established by the client and Isthmus Partners. At the commencement of services, the firm reviews the client’s investment objectives and risk tolerance. Based upon that review and other information provided by the client, Isthmus Partners makes a subsequent recommendation to the client as to which investment style the firm believes is best suited for the client. The client makes the final decision as to which investment style is chosen for the client’s account. For its discretionary asset management services, the firm receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 6.C.7 of this brochure. In addition to providing Isthmus Partners with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are obligated to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. On a quarterly basis, Isthmus Partners’ reports to clients will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Isthmus Partners will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. A.2. Fees and Compensation Counseled Portfolios The following fee schedule sets forth the maximum fee rates for Counseled Portfolios. Value of Assets Annual Fee Rate First $2 million 1.25% Next $3 million 1.00% Next $5 million 0.80% Over $10 million 0.60% The minimum asset value to open a Counseled Portfolio is typically $2 million. The minimum annual advisory fee is generally $25,000. For Counseled clients seeking fixed-income management only, fees are negotiable. International equity securities management and portfolio of mutual fund portfolios is only available to Counseled Portfolios as part of a larger diversified portfolio. The firm will calculate a client’s advisory fee by applying the applicable fee rate to the value of all of the assets in the client’s account, including cash and its equivalent and including all assets held by any third party custodian. If requested by a client and approved by Isthmus Partners a client’s advisory fee may be determined by also including the aggregate value of assets in certain other accounts held by a client and the client’s immediate family members residing in the same household, which may include managed account assets held in a client’s name at Isthmus Partners and may include at the firm’s discretion, assets held away from Isthmus Partners non-managed assets, and assets held in a name other than that of the client. A client should note that retirement accounts may not be included in to the extent a prohibited transaction under ERISA or the IRC may result. The terms of any such household fee arrangement will be set forth in the client’s investment management agreement. The advisory fee and minimum account value are negotiable in certain instances and may vary based upon a number of factors, including but not limited to the size and nature of the assets in the client’s account, the client’s particular investment style or objective, and any particular services requested by the client. In some instances, clients may pay a higher fee than indicated in the fee schedules above. Asset-based fees are always subject to the investment advisory agreement between the client and Isthmus Partners. Such fees are payable quarterly in advance. The fees will be prorated if the investment advisory relationship commences otherwise than at the beginning of a calendar month. These fees include charges for all transaction costs such as commissions on purchase and sales of stocks, bonds, exchange-traded funds and options, and mutual fund transactions fees. Except as otherwise provided below, client will incur no charges other than the adviser’s fee pursuant to the above fee schedule in connection with the maintenance of and activity in client’s account. The wrap fee does not include annual account fees or other administrative fees, such as wire fees, charged by manager or brokerage firm; fees for securities transactions executed away from the custodian; certain odd-lot differentials, transfer taxes, transaction fees mandated by the Securities Act of 1934, postage and handling fees, and charges imposed by law with regard to transactions in the client’s account; and advisory fees, expenses or sales charges (loads) of mutual funds (including money market funds), closed-end investment companies or other managed investments, if any, held in client’s account. The wrap fee also does not cover certain costs associated with securities transactions in the over-the-counter market, such as fixed income securities where manager must approach a dealer or market maker to purchase or sell a security. Such costs include the dealer’s mark-up, mark-down or spread and odd-lot differentials or transfer taxes imposed by law. The trading cost component of the Isthmus Partners’ advisory fee is estimated to range from $0 to $500 per account per year. The client authorizes the qualified custodian to automatically deduct the fee and all other charges payable hereunder from the assets in the account when due with such payments to be reflected on the next account statement sent to the client. If insufficient cash is available to pay such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. Isthmus Partners may modify the fee at any time upon 30 days’ written notice to the client. In the event the client has an ERISA-governed plan, fee modifications must be approved in writing by the client. A client investment advisory agreement may be canceled at any time by the client, or by Isthmus Partners with 30 days’ prior written notice to the client. Upon termination, any unearned, prepaid fees will be promptly refunded. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. B. Disclosure of Cost Difference if Services Purchased Separately Depending

on a number of factors, such as the number, size, and nature of the securities transactions in an advisory account, the overall fees and charges borne by the client over time could be more or less than what these fees and charges would be if the same services were provided on a separate basis, either as asset-based fees or transaction-based fees. Bundled fees (where the adviser assumes the cost of processing the trade) generally provide an economic incentive for the advisory firm to select investments and strategies that minimize trading costs. Frequent trading in an account where transactions fees are included as part of the overall advisory fee to the client drive trading costs higher and reduce the overall fee revenue to the advisor. As a result, higher trading costs in a bundled fee account have a negative impact on the advisory firm’s profitability. C. Additional Client Fees and Terms of Payment C.1. Client Payment of Fees Isthmus Partners requires clients to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. Isthmus Partners will deduct its advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. C.2. Prepayment of Client Fees Isthmus Partners generally requires fees to be prepaid on a quarterly basis. Isthmus Partners’ fees will either be paid directly by the client or disbursed to Isthmus Partners by the qualified custodian of the client’s investment accounts, subject to prior written consent of the client. The custodian will deliver directly to the client an account statement, at least quarterly, showing all investment and transaction activity for the period, including fee disbursements from the account. A client investment advisory agreement may be canceled at any time by the client, or by Isthmus Partners with 30 days’ prior written notice to the client. Upon termination, any unearned, prepaid fees will be promptly refunded. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. C.3. Additional Fees All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and exchange-traded funds. Such fees and expenses are described in each fund’s prospectus. Clients are advised to read these materials carefully before investing. Please refer to the Brokerage Practices section (Items 9.B. and 9.B.) for additional information regarding the firm’s brokerage practices. D. Compensation for Recommending the Isthmus Partners Wrap Fee Program The Isthmus Partners Wrap Fee Program is a proprietary product offered exclusively through Isthmus Partners. As such, there are no conflicts of interest in that there are no commissions paid for selling the Isthmus Partners Wrap Fee Program. E. External Compensation for the Sale of Securities to Clients Isthmus Partners’ advisory professionals are compensated solely through a salary and bonus structure. Isthmus Partners is not paid any sales, service or administrative fees for the sale of mutual funds or any other investment products with respect to managed advisory assets. F. Important Disclosure – Custodian Investment Programs Please be advised that the firm utilizes certain custodians/broker-dealers. Under these arrangements we can access certain investment programs offered through such custodian(s) that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. Please note the following: Limitation on Mutual Fund Universe for Custodian Investment Programs: There are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm clients. Additional Disclosure Concerning Wrap Programs: To the extent that we either sponsor or recommend wrap fee programs, please be advised that certain wrap fee programs may (i) allow our investment adviser representatives to select mutual fund classes that either have no transaction fee costs associated with them but include embedded 12b-1 fees that lower the investor’s return (“sometimes referred to as “A-Shares,” depending on the mutual fund issuer), or (ii) allow the use of mutual fund classes that have transaction fees associated with them but do not carry embedded 12b-1 fees (sometimes referred to as “I-Shares,” depending on the mutual fund sponsor). Wrap fee programs offer investment services and related transaction services for one all-inclusive fee (except as may be described in the applicable wrap fee program brochure). The trading costs are typically absorbed by the firm and/or the investment representative. If a client’s account holds A-Shares within a wrap fee program, the firm and/or its investment adviser representative avoids paying the transaction fees charged by other mutual fund classes, which in effect decreases the firm’s costs and increases its revenues from the account. Effectively, the cost is transferred to the client from the firm in the form of a lower rate of return on the specific mutual fund. This creates an incentive for the firm or investment adviser representative to utilize such funds as opposed to those funds that may be equally appropriate for a client but do not carry the additional cost of 12b-1 fees. As a policy matter, the firm does not allow funds that impose 12b-1 or revenue sharing fees on the client’s investment within its wrap fee programs. Clients should understand and discuss with their investment adviser representative the types of mutual fund share classes available in the wrap fee program and the basis for using one share class over another in accordance with their individual circumstances and priorities. G. Client Assets Under Management As of December 31, 2022, Isthmus Partners had $977,296,272 of discretionary assets under management and $0 of non-discretionary assets under management. Item 5: Account Requirements and Types of Clients