A. Description of the Advisory Firm Crewe Advisors LLC is a Limited Liability Company organized in the State of Utah and conducts its business under the DBA name of Crewe Advisors (hereinafter referred to as “CA”). The firm was formed in December 2014. The principal owners of the firm are HH2007, LLC, Tidus, LLC, Pin High, LLC, Crewe Holdings, LLC, and T2, LLC. Ryan Halliday, Managing Member, owns HH2007, LLC. Daniel Sudit, Managing Member, owns Tidus, LLC. Crewe Holdings, LLC and Pin High, LLC are controlled by Michael Bennett, Investment Adviser Representative. T2, LLC is owned by Dustin Thackeray, Chief Investment Officer. B. Types of Advisory Services Portfolio Management Services CA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: ▪ Investment strategy ▪ Asset allocation ▪ Risk tolerance ▪ Personal investment policy ▪ Asset selection ▪ Regular portfolio monitoring CA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. With respect to publicly-traded securities, such as mutual funds, exchange-traded funds, and individual equity and fixed-income securities, as well as some privately-traded securities, CA will request discretionary authority from clients in order to select these types of securities and execute transactions without permission from the client prior to each transaction. In cases where CA recommends a private fund or other pooled investment vehicle that has a selling agreement with a related person of CA, CA will obtain the client’s consent before investing in the security so as to help mitigate any conflict of interest. Risk tolerance levels provided by clients are documented in the Investment Policy Statement. CA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CA’s economic, investment or other financial interests. To meet its fiduciary obligations, CA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment C R E W E A D V I S O R S F O R M A D V P A R T 2 A – V . 0 3 . 2 8 . 2 4 2 opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. CA does not limit its advice to any particular types of securities. With regard to held away assets, such as defined contribution plan participant accounts, CA may use a third-party platform to facilitate management of these accounts on a discretionary basis. CA will not have direct access to client log-in credentials to affect trades using this platform. CA is not affiliated with the platform in any way and receives no compensation from the company making available the platform. Selection of Other Advisers CA may direct clients to separately managed accounts (SMA) managed by third-party money managers. CA may be compensated via a fee share from the advisors to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other advisors for clients, CA will ensure those other advisors are properly licensed or registered as an investment advisor. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance;

tax concerns; retirement planning; college planning; and debt/credit planning (collectively “Financial Planning”). The agreement for Financial Planning is referred to as the "Comprehensive Planning Agreement”. Retirement Rollovers A client leaving an employer typically has four options (and may engage in a combination of these options): I. Leave the money in their former employer’s plan, if permitted, II. Roll over the assets to their new employer’s plan, if one is available and rollovers are permitted, III. Rollover to an IRA, or IV. Cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). CA may recommend an investor roll over retirement plan assets to an Individual Retirement Account (IRA) managed by CA. As a result, CA and its advisors may earn an asset-based fee on those assets. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Specifically, if CA recommends a client roll over its retirement assets to a CA managed account, such a recommendation creates a conflict of interest if CA will earn new (or increase its current) compensation as a result of the rollover. Depending on the options available to the individual, rolling over assets to a CA managed account could incur higher fees than leaving it in a current plan or moving to another employer-sponsored plan. In contrast, a recommendation that a client or prospective client leave their plan assets with their old employer or roll the assets to a plan sponsored by a new employer will generally result in no compensation to CA. CA has an economic incentive to encourage an investor to roll plan assets into an IRA that CA will manage. C R E W E A D V I S O R S F O R M A D V P A R T 2 A – V . 0 3 . 2 8 . 2 4 3 There are various factors that CA may consider before recommending a rollover, including but not limited to: I. The investment options available in the plan versus the investment options available in an IRA, II. Fees and expenses in the plan versus the fees and expenses in an IRA, III. The services and responsiveness of the plan’s investment professionals versus CA’s, IV. Protection of assets from creditors and legal judgments, V. Required minimum distributions and age considerations, VI. Employer stock tax consequences, if any, VII. Plan’s withdrawal options or limitations, before and/or after retirement No client is under any obligation to rollover retirement plan assets to an account managed by CA. C. Client Tailored Services and Client Imposed Restrictions CA offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CA from properly servicing the client account, or if the restrictions would require CA to deviate from its standard suite of services, CA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. CA does not participate in any wrap fee programs. E. Assets Under Management CA has the following assets under management: Discretionary Amount: Non-discretionary Amount: Date Calculated: $1,609,607,658 $10,886,401 December 31, 2023