A. Swan Global Management, LLC (hereinafter “Swan”, “we”, “our”, “us”, or the “Firm”), is majority owned by Randall W. Swan, and w i t h Swan affiliated f i r m s has been offering investment management services since 1997. Swan is an independent Investment Adviser headquartered in Puerto Rico. Swan is registered with the US Securities and Exchange Commission (“SEC”) under the Investment Advisors Act of 1940 (“Advisors Act”). Swan offers and manages The Defined Risk Strategy for its clients including individuals, institutions and other investment advisor firms. Swan also acts as sub- advisor to the Swan mutual funds and ETFs. B. Swan provides discretionary investment management through a strategy called the Defined Risk Strategy (“DRS”). As detailed in Item 8, the DRS is in an index-based strategy that was designed to protect investors from substantial market declines, provide income in flat, up, or down markets, and to benefit from market appreciation. The DRS’s core equity holdings depend on the product, but for the primary DRS products, they are S&P 500 correlated securities through exchange traded funds. Options on these indices are additional primary components of the strategy. Options are used to protect the main holdings in down markets and also to generate monthly income for the portfolios. C. Swan is in the process of introducing new investment strategies and products derived from the DRS process. Our investment team has preferred investment guidelines for each Strategy. On some occasions, we may negotiate with clients and customize investment guidelines, including accepting additional or different limitations if we believe we can effectively manage the account. Our investment team creates and maintains model portfolios based on their preferred benchmarks and guidelines. Investment guidelines that differ significantly from our preferred guidelines may result in exclusions or variances in holdings from the team’s model portfolio that may take additional time for the team to determine alternative holdings or weights for more restricted accounts. Trades to implement changes to accounts managed in line with a Strategy’s model portfolio may be placed earlier than trades for more restricted accounts. As a result, trades for accounts with materially different restrictions could experience different execution prices and different performance than less restricted accounts based on the exclusions and time delay in trade placement. Such restricted accounts also may be placed in a separate performance composite from less restricted accounts in a similar Strategy. Different Swan DRS product offerings include:
• Swan DRS standard strategy (S&P 500) – The Swan DRS for the S&P 500 is generally offered and managed only for discretionary clients and not tailored to the individual needs or requests of the clients. The DRS strategy varies slightly for regular (or taxable) accounts and IRA accounts due to regulatory options restrictions placed on IRA accounts.
• Swan Overlay Strategy – the Swan DRS Overlay strategy enhances an existing large underlying asset position by creating additional protection and/or income for the clients.

• Swan Mutual Funds & ETFs – Swan offers the DRS in mutual funds and ETFs using essentially the same DRS strategy for various asset classes, such as the S&P 500, emerging markets, etc.
• Other products that Swan is focused on include a DRS strategy placed on other asset classes besides the S&P 500, such as emerging markets, developed markets, small caps, etc. and in different venues. D. Swan does not sponsor any wrap fee programs or utilize any wrap fee programs for clients. However, Swan has third party advisor relations that use and sponsor wrap fee programs that incorporate the Swan DRS strategy as SMA accounts into the wrap fee program. Investment management provided to sub- advised wrap fee clients is substantially the same as that provided to non-wrap fee clients. However, practical restraints to the management of wrap fee accounts may exist. Most notably, the smaller asset value of certain wrap fee accounts and IRA accounts may result in slightly different returns due to investment limitations imposed by options restrictions, administrative restrictions, and wrap fees imposed by wrap fee sponsors. For sub-advised clients and wrap fee clients whose accounts are managed by Swan pursuant to a wrap-fee, consulting, or other referral program, advisory and wrap fee services may be provided by the third-party broker-dealer, investment advisor, trust company or other financial services provider who sponsors the program and advises the client. Under these arrangements, the financial services provider typically interviews the client or has the client complete a written questionnaire, assesses the client's financial situation and financial needs and makes a determination as to whether the investment styles and services offered by Swan and the DRS investment strategy would be appropriate for the client before Swan is retained to manage the client's account. The financial services provider also normally is responsible for determining and notifying Swan of any changes in the client's investment objectives or personal or financial circumstances that should be taken into account in managing the account. Similar to Swan clients, sub- advised clients have Swan imposed account restrictions such as a minimum investment levels and option approval levels. If clients cannot meet these restrictions or fall out of certain restriction thresholds, then Swan reserves the right to terminate the management of the account. Swan manages client assets mostly on a discretionary basis. As of December 31, 2023, Swan Global Management, LLC, managed and sub-advised AUM of $2,105,953,989 which consists of $710,578,113 AUM in Separately Managed Accounts (“SMAs”), $7,333,824 in overlay accounts, and as affiliate and sub-advisor to Swan Capital Management, LLC, which is the Swan mutual funds and ETF adviser with AUM of $873,210,427 in mutual funds and $514,831,625 in ETFs. This is the entire amount of assets under our discretion as computed by our client accounting software (Orion). All account data is downloaded on a daily basis from the brokerage firms holding custody of the client assets (Charles Schwab, US Bank, Goldman Sachs, Pershing, etc.).