A. Firm Description Proficio Capital Partners LLC, a Delaware limited liability company was formed on August 6, 2014 (“Proficio”) to provide discretionary investment advisory services to the founder’s families as a private family office. Proficio has been offering investment advisory services to high-net-worth families and individuals that are not related to Proficio’s founders since September 2015. Robert Haber and Matthew Wosk are the founders of Proficio. Matthew Wosk is the principal owner and managing member (members are hereafter referred to as partners or partner). Key employees are admitted to partnership in Proficio from time to time. B. Types of Advisory Services Proficio provides investment advisory services to businesses, foundations, and endowments and to other investment advisors as a sub-advisor. Proficio provides sub-advisory services to privately placed, insurance-dedicated investment funds as well as to Canadian investment advisors. Proficio sponsors, administers, and advises private pooled investment vehicles (“Private Funds”) to invest in one or more illiquid investments requiring significant capital to purchase, to spread risk, enable exposure at lower investment amounts, and to reduce the administrative burden imposed on clients who would otherwise have to invest directly in the various funds and investments that Proficio recommends. Proficio provides oversight of assets managed by other advisers. C. Discretionary Investment Advisory Services Proficio provides highly personalized investment services through its portfolio managers who are assigned to each client. Proficio may either have full discretion over client assets and will invest these assets in accordance with Proficio’s investment processes as described in Item 8 or Proficio may work in collaboration with knowledgeable clients who want more involvement constructing their portfolios. The extent of client involvement will vary from clients that are not involved, clients that desire a veto over individual investments while largely remaining within Proficio’s recommended portfolios, to clients that use Proficio’s advice as suggestions to build their investment portfolios while utilizing Proficio’s other services. Prior to advising or making investment allocations on behalf of a client, Proficio will attempt to learn as much as possible about the client’s personal and family situation including the expected financial needs for the next generations of the client’s family. Proficio’s portfolio managers will also review the client’s current levels of taxation, risk tolerance as well as the other investments that a client may hold, including non- investment assets such as businesses and real estate. This information forms the basis of a holistic evaluation that determines the type of investment portfolio Proficio will manage for the client. Proficio, the portfolio manager and the client will periodically review the portfolio to ensure it continues to meet the client’s needs. All portfolios Proficio offers start with a core investment portfolio developed by the Chief Investment Officer and Proficio’s research department and varied accordingly. At least one of Proficio’s partners or a member or their family must invest in each investment in the core investment portfolio that Proficio clients invest in (and in the Private Funds that Proficio sponsors). There are four versions of the core investment portfolio offered to clients. These are: a) a conservative and income oriented portfolio that may have higher taxes, b) a longer-term growth oriented portfolio adhering closely to the core investment portfolio and implementing Proficio’s best tactical and strategic ideas, c) an aggressive version of the general longer-term growth portfolio but with a higher tax burden, and d) a portfolio built in conjunction with clients with reference to Proficio’s core investment portfolio and investment strategies as modified by the client. Portfolio managers are charged with making the necessary adjustments to the core portfolio with respect to investment selection among the core portfolio options, asset allocation (within guidelines), and portfolio monitoring to meet the client’s needs. Proficio seeks to tailor its investment advisory services based on the client’s other assets (such as legacy securities and non-Proficio advised assets) owned by its clients. For example, an investment in a Real Estate Investment Trust that buys office buildings may not be appropriate for clients with a portfolio that contains direct investments in office buildings. Proficio will apply its quantitative and derivative experience to client needs and may create customized hedges or other sophisticated transactions to address portfolio issues on behalf of its clients, and to seek to gain or mitigate exposure in the market for groups of clients where other methods are not as practical (for tax or other reasons). Institutional clients will have access to the full range of services provided by Proficio and in certain situations Proficio may serve as their external Chief Investment Officer and investment staff. Proficio will not develop the same holistic understanding or assign a portfolio type for institutional clients as it does with individuals and families but will operate within the investment parameters established with the client. Proficio will consider investments that are generally liquid (for which a market exists) and less-liquid investments such as hedge funds with redemption restrictions, provided that any restrictions do not exceed 90 days (with 45 days prior notice and payment within 5 to 10 days after the restriction period) for the core portfolio investments. Proficio will also consider investments outside of the core portfolio for its clients subject to redemption restrictions for periods greater than 90 days depending on the client’s tolerance for risk and ability to withstand the long periods of illiquidity of portions of their portfolio. For certain clients Proficio may recommend illiquid investments such as hedge funds, private equity, real estate, and Opportunity Zone investments (as described below) on a case-by-case basis especially where the client has requested exposure to higher-risk, illiquid assets. Private Funds Proficio has created Private Funds that make multiple investments in long-term, illiquid, higher risk assets as well as alternative investments (such as music royalties) that have varying degrees of illiquidity. Certain of these Private Funds are intended to be held for up to ten years, and possibly longer, if the investments do not perform as expected, while other Private Funds are redeemable twice a year or quarterly depending on the share class. Proficio serves as the general partner or managing member as well as investment advisor for its Private Funds. See Item 15, Custody. Proficio may not form a Private Fund using assets purchased from its clients, their families, or affiliates of Proficio. a) Single Investment Private Funds: Single investment Private Funds Proficio sponsors will

invest in a private investment, and subsequent classes of interests issued after the initial investment, that are considered illiquid (subject to restrictions of more than 90 days and for which a limited market exists) and that are only available to sophisticated investors. Proficio will analyze and review these investments to determine if they are suitable. Clients may invest in a Proficio Private Fund after they have reviewed the investment, fees, and disclosure documents and complete a subscription. b) Multiple Investment Private Funds: Proficio will designate a portfolio of investments to achieve a specific objective (for example a fund that seeks to purchase investments expected to perform in market environments where fixed-income investments underperform). To save on administrative and transaction costs, Proficio will acquire these investments through a limited partnership or limited liability company or a limited liability company series and allocate a percentage of the entity to participating clients. Clients will approve the investment after their review through an initial subscription and thereafter Proficio may allocate Client assets in accordance with the Client’s needs. Private Funds will contain long-term investments with limited liquidity but may also contain underlying investments that allow the fund to offer more frequent redemption periods, such as quarterly. At least one Proficio partner or a member of their family must invest in each Private Fund Proficio offers. Opportunity Zone Investments Opportunity Zones, added to the United States Internal Revenue Code by the Tax Cuts and Jobs Act on December 22, 2017, are economically distressed communities where new investments, under certain circumstances, may be eligible for preferential tax treatment. Localities are designated as Opportunity Zones after nomination by the state and certification by the Internal Revenue Service. Proficio has invested client assets, where appropriate, in certain Qualified Opportunity Zone Funds. Investors must remain invested in a Qualified Opportunity Zone company for at least ten years to take advantage of the full tax benefits and should not expect to liquidate their investment without a substantial discount independently of the planned exit of all the investors or prior to the ten-year holding period. Legacy Securities In certain instances, clients will already hold publicly traded equity securities in their portfolios that they are unwilling to sell. In these situations, Proficio will monitor the holdings and may recommend when the client should consider selling the security based on the client’s personal situation, their portfolio diversification needs, risk tolerances, financial, investment needs and other considerations (such as to offset tax gains). Proficio may suggest actions to be taken with respect to these securities, but it will generally not have investment discretion and ultimately the client will have to direct or approve any transaction. Proficio will take these holdings into account when making other discretionary investment decisions with respect to the client’s portfolio. Structured Notes Proficio may review, price, and facilitate the purchase of structured notes to: a) hedge an asset category in the core portfolio for a group of clients, b) in a Proficio advised Private Fund where consistent with the Private Fund’s investment requirements, or c) for investment at the request by clients who are actively involved in their portfolios. Structured notes are debt securities issued by financial institutions that offer a return based on underlying securities, interest rates, commodities, or currencies. Proficio generally only recommends structured notes based on passive index ETFs unless a note tied to a specific company serves as a better hedge. Certain sophisticated clients may specifically request structured notes based on single name equities. Notes based on single name equities are not made available to all clients and are not subject to Proficio’s Chief Investment Officer and research staff review. When purchased for sophisticated clients in this fashion, structured notes will not receive a suitability review and are not subject to the requirements other investments for Proficio clients must satisfy. These structured note purchases are not subject to the requirement that Proficio partners or their families participate in the investment. Clients that hold structured notes based on single name equities are required to periodically acknowledge the risks in writing. See Item 8.C. for structured note risk factors. Initial Public or Follow-on Offerings and SPACs From time-to-time Proficio may have the opportunity to purchase shares in initial public offerings, follow-on offerings, or block trades on behalf of its clients. Proficio partners, officers and employees may not participate in such offerings. Proficio will allocate the offering shares among its clients that have authorized Proficio to participate on their behalf and who are not otherwise prohibited from participation. Proficio will base each client’s allocation on the percentage of total assets under management of the client’s account with Proficio. When four or more clients are participating in an offering, no client, despite its size, will receive over 50% of the total offering allocated to Proficio. Proficio will allocate shares with “trade away” and other costs in mind. For example, if a client receives a small number of shares based on the foregoing process and a sale will incur an excessive trade away commission that may significantly reduce or eliminate any profit from the trade, then Proficio may in its sole discretion skip the allocation as not cost-effective and direct the allocation to another client. In some cases, it may be appropriate for one or more clients to hold an initial public offering for longer periods than other clients or in accounts that Proficio does not manage. Proficio may use that factor in determining the allocation those clients receive. For small allocations, generally under $150,000, Proficio has determined that the costs of the trade and the associated risk do not justify splitting the trade among a group of clients. In that case, the entire allocation will generally be allocated to the privately placed, insurance dedicated fund Proficio sub-advises. Proficio has determined that the risks associated with Special Purpose Acquisition Companies (SPAC) shares make them unsuitable for most clients. However, Proficio will acquire SPAC shares for the insurance dedicated fund that it sub-advises and for certain clients on the client’s direction. Proficio does not provide legal or tax advice but will work together with a client’s legal and tax advisors when warranted. D. Wrap Fee Programs At the current time, Proficio does not participate in any wrap fee programs. E. Client Assets Under Management As of December 31, 2023, Proficio managed assets in the amount of $2.57 billion on a discretionary basis. Proficio managed $399 million on a non-discretionary basis.