A. GENERAL DESCRIPTION Almanack Investment Partners, LLC ("Almanack" or “Advisor”) is a Delaware limited liability company formed on September 14, 2015. Almanack is principally owned by Gadsden Group Holdings, LLC. The Advisor's core business is to offer investment management services to individual and institutional clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal (the "Core Allocation"). Almanack offers its services through a number of independently owned offices located across the United States. As discussed below, Almanack offers to its clients (individuals, high net worth individuals, state or municipal entities, trusts, estates, and charitable organizations, etc.) investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. In addition, Almanack also provides services to other investment advisers in the form of sub-advisory and consulting. Almanack manages advisory accounts on a discretionary or non-discretionary basis through relationships with Charles Schwab & Company, Inc. (“Schwab”), Fidelity Investments (“Fidelity”), Pictet Asset Services (“Pictet”) and Interactive Brokers (“IB”). Almanack’s annual investment advisory fee may be either fixed or based upon a percentage (%) of the market value of the assets placed under Almanack’s management. Through personal discussions with the client in which the client's goals and objectives are established, Almanack Investment Adviser Representatives determine which model portfolio is best suited to the client's individual needs and objectives. The Advisor's Core Allocation starts by forming a fundamental understanding of the primary drivers of potential portfolio exposures and emphasizes the development of methods for combining these exposures (often index based) into a diversified risk conscious portfolio. Once Almanack determines the suitability of the portfolio, the portfolio is managed based on the portfolio's intended objective. Clients are permitted to place reasonable restrictions on the types of investments to be held in their account as long as such restrictions do not materially interfere with Almanack’s ability to effectively manage client assets. Clients retain individual ownership of all securities. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity needs and overall suitability. To ensure that Almanack’s initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, Almanack will: 1. At least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 2. Be reasonably available to consult with the client; and 3. Maintain client suitability information in each client's file. In addition, Almanack provides an internal platform for Almanack investment adviser representatives (“IARs”) to access investment management, business consulting and operational support services. These IARs share resources, ideas and other best practices within the platform and deliver investment advice, insurance solutions and other financial services to their own individual and institutional clients in the investment advisor community. In addition to the services described above, Almanack also offers Investment Management Services as described below at Item 4.B. including consulting services. Each of these businesses are described in more detail below. B. INVESTMENT MANAGEMENT SERVICES Almanack may be engaged to provide discretionary or non-discretionary investment advisory services. Almanack’s investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Almanack’s management and generally ranges from .25% to 2.0% annually. Almanack’s annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. Almanack supports its own investment management platform (the "Platform") that is available to the IARs of Almanack. Before engaging Almanack to provide investment advisory services, clients are required to enter into an Investment Management Agreement (“IMA”) with Almanack setting forth the terms and conditions of the engagement (including termination, describing the scope of the services to be provided, and the fee that is due from the client). To commence the investment advisory process, an IAR will first ascertain each client’s investment objectives and then allocate and/or recommend that the client allocate investment assets consistent with their designated investment objectives. Once client assets are allocated, Almanack provides ongoing monitoring and review of account performance and asset allocation. Almanack shall have discretionary authority to engage unaffiliated investment managers and serve as an overlay portfolio manager to construct, allocate and reallocate investment portfolios for clients of Almanack IARs. Almanack also provides the following services, either directly or through contractual relationships with third parties, with respect to the Platform:
• Investment model administration and Manager facilitation services
• Advisor as Portfolio Manager ("APM") functionality, account administration, billing and reconciliation, account aggregation, reconciliation and reporting, and client account reporting
• Business management reporting technology services Investment Services The Advisor offers compliance, operational and back-office support to its IARs through third party service providers. These services are typically funded through the fees charged by the IAR to its clients. As part of these services to the investment advisor, Almanack provides the IARs with access to a range of investment advisory services for use by advisors with their clients, including Separately Managed Accounts ("SMA"), Mutual Funds and Exchange Traded Funds ("ETF") Asset Allocation Strategies and Unified Managed Accounts ("UMA") (each an "Investment Program" and collectively, the "Investment Programs"). The Investment Programs are generally made available by Almanack to their IARs, who may recommend one or more Investment Programs to their clients. A client's investment adviser determines which services and Investment Programs of Almanack to use with its clients and may use the services of other third-party service providers in conjunction with the Investment Programs. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) Consulting Services Almanack offers a range of consulting services including allocation research, risk analysis, benchmarking, and manager assessment. These services are provided pursuant to specialized engagements individually negotiated with Almanack’s clients based upon their specific needs and objectives. In performing its services, Almanack is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is authorized to rely on such information. Almanack may recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Almanack recommends its own services or the services of any of its Advisory Affiliates (as set forth in Item 10). The client is under no obligation to act upon any of the recommendations made by Almanack under a consulting engagement or to engage the services of any such recommended professional, including Almanack itself. The client retains discretion over all such implementation decisions and is free to accept or reject any of Almanack’s recommendations. Clients are advised that it remains their responsibility to promptly notify Almanack if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Almanack’s previous recommendations and/or services. Financial Planning To the extent specifically requested by a client, Almanack may provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Almanack's planning and consulting fees are charged either at an hourly rate or up to 1% of the client's total net worth, subject to a minimum of $1,000; however, discounted rates can and may be offered. The fees charged are dependent upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging Almanack to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Almanack setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Almanack commencing services. If requested by the client, Almanack will recommend the services of other professionals for implementation purposes, including Almanack’s representatives in their individual capacities as registered representatives of a broker-dealer, or licensed insurance agents. (See disclosure at Item 10.C.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Almanack. It remains the client’s responsibility to promptly notify Almanack if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Almanack’s previous recommendations and/or services. Financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact, and are impacted by, the entire financial and life situation of the client. Clients purchasing this service either receive a written report or access to software which provides the client with a detailed financial plan designed to assist the client in achieving his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: Almanack reviews family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: Almanack analyzes the client's income tax and spending and planning for past, current, and future years; then illustrates the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: Almanack analyzes investment alternatives and their effect on the client's portfolio.
• INSURANCE: Almanack reviews existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile.
• RETIREMENT: Almanack analyzes current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: Almanack reviews the client's cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: Almanack assists the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid, and elder law. Almanack gathers required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. Almanack carefully reviews documents supplied by the client, including a questionnaire completed by the client, and prepares a written report. Should the client choose to implement the recommendations contained in the plan, Almanack suggests the client work closely with their attorney, accountant, insurance agent, and/or investment adviser. Implementation of financial plan recommendations is entirely at the client's discretion. Almanack also provides general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Investment recommendations in financial plans may include any or all of the following:
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund share
• United States governmental securities
• Options contracts on securities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas interests
• Any investments held by the client at the inception of the advisory relationship Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature and should be reviewed with your attorney, accountant or other professional as appropriate prior to implementation. SIGNAL PROVIDER Almanack may be selected by third-party investment advisors to serve in the capacity as a signal-provider to their client accounts. When selected as a signal-provider, Almanack will develop and provide the third- party advisor with signals and recommendations for when to buy and sell investments. Almanack will provide signals on a non-discretionary basis to those third-party advisor accounts. As such, Almanack has no investment discretion, no knowledge of the underlying investment advisor’s clients, no authority to effect and/or execute trades on behalf of the third-party advisor’s clients and no knowledge as to whether the third-party advisor followed any of the signals provided. This means the third-party advisor will trade their client accounts to implement the signals provided by Almanack. The third-party investment adviser will maintain discretionary authority on the account to place trades and make changes to the account or the portion of the account based on the signal provided by Almanack. It is important to note Almanack manages investments and accounts for other clients and gives them advice or takes action for them or for our personal accounts that may be different from the signals we provide to such third-party advisors. Almanack is not obligated to buy, sell or recommend to a third-party advisor any security or other investment that it may buy, sell or recommend for any other clients or for Almanack’s own accounts. The fees for signal provider services are agreed upon by the third-party investment adviser and Almanack. The agreement will state the manner, amount and timing of Almanack’s compensation. Generally, compensation will be based upon the value of the assets to which a signal is being applied. Such fees may be higher, or lower than those paid by Almanack clients who are not in such arrangements. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: As indicated above, to the extent requested by the client, Almanack may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Almanack is not a law firm or accounting firm, and no portion of its services should be construed as legal, tax or accounting advice. Accordingly, Almanack does not prepare estate planning documents or tax returns. To the extent requested by a client, Almanack may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.), including representatives of Almanack in their separate individual capacities as registered representatives (individually and/or collectively, “Third Party BD”), each a FINRA member broker-dealer and/or as insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Almanack and/or its representatives (See Item 10 below). The recommendation by Almanack’s representative that a client purchase a security or insurance commission product in his/her separate and individual capacity as a registered representative of a Third-Party broker dealer, and/or as an insurance agent, presents a conflict of interest, as the receipt of commissions provides an incentive to recommend investment or insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission products through such representative. Clients are reminded that they may purchase securities or insurance products recommended by Almanack through other, non-affiliated broker-dealers or insurance agencies. Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in one or a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which would, depending upon the client’s age, result in adverse tax consequences). If Almanack recommends that a client roll over their retirement plan assets into an account to be managed by Almanack, such a recommendation creates a conflict of interest as Almanack will earn new (or increase its current) compensation as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account

managed by Almanack. When Almanack provides investment advice to you regarding your retirement plan account, individual retirement account, or other qualified asset under ERISA, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security 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 Almanack operates under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Clients can engage Almanack to provide either education or recommendations with respect to qualified ERISA assets including:  from a qualified plan to an IRA;  from an existing third-party IRA to an IRA;  changing the account type of an existing IRA;  from a qualified plan to another qualified plan; and  from an IRA to qualified plan rollover. Such provisions also extend to other qualified assets such as Education Savings Accounts and retirement annuities. Clients should fully understand all of the conflicts, risks, costs & expenses, as well as potential benefits associated with moving qualified retirement assets. Clients are under no obligation to accept or follow Almanack’s recommendations. Unaffiliated Private Funds Almanack may also provide investment advice regarding unaffiliated private investment funds. Almanack, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Almanack’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Almanack calculating its investment advisory fee. Almanack’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Affiliated Private Fund Almanack is the investment adviser to Almanack Alpha Fund LP (“AAFLP” or the “Fund”) which is an unregistered investment company organized as a limited liability corporation and sponsored by Almanack. Almanack also serves as a General Partner to AAFLP. As noted above, Almanack is affiliated with AAFLP, the complete description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the Fund’s offering documents. Almanack, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to the Fund. The terms and conditions for participation in the affiliated fund, including management fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents. Almanack’s clients are under absolutely no obligation to consider or make an investment in AAFLP. The investment objective of the Fund is to invest in other funds which seek to achieve above-average capital appreciation, lack of correlation to traditional markets, and low volatility returns for its clients by investing in a broadly diversified portfolio of alternative investment opportunities. While there are no substantive limits on the investment strategies that may be pursued by the Fund, it is anticipated that the Fund will seek to leverage the Advisor’s expertise to identify, invest, and manage a select suite of investment opportunities. The Fund will utilize the Advisor’s relationships, contacts, and knowledge for the benefit of the strategy. It seeks to provide consistent long-term returns. Income is not an objective. In providing advisory services to the Fund, Almanack directs and manages the investment and reinvestment of the Fund's assets and provides reports to investors (through the Funds' administrator). Almanack manages the assets of the Fund in accordance with the terms of its governing documents. AAFLP is a Fund of Hedge Funds. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in the Fund's offering documents, which will be provided to each client for review and consideration. Unlike other liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client that elects to invest in the Fund will be required to complete a Subscription Agreement, pursuant to which the client shall establish that the client is qualified to invest in the Fund and acknowledges and accepts the various risk factors that are associated with such an investment. In the event that Almanack references private investment funds owned by the client on any supplemental account reports prepared by Almanack, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. If the fund sponsor does not provide a post-purchase valuation, then the valuation shall reflect the initial purchase price (and/or a value as of a previous date) or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects the initial purchase price (and/or a value as of a previous date), then the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. The client’s advisory fee shall be based upon such reflected fund value(s). The affiliated Fund generally invests in unaffiliated private investment funds. As such, a client will incur separate management fees: (1) the fee charge by the underlying unaffiliated private investment funds; (2) the advisory fee charged by Almanack (the amount invested in the affiliated funds will be included as part of the client’s assets under management (see Item 5 below) for purposes of calculating Almanack’s fee; and (3) the management fee charged by AAFLP itself. Because the Advisor earns compensation from the AAFLP, Almanack's advisory fee may, in the aggregate, exceed the fee that it would earn under its standard "assets under management" fee schedule referenced in Item 5A below absent a client’s investment in AAFLP. The recommendation that a client become an investor in AAFLP presents a conflict of interest, but clients are under no obligation to become an investor in any Almanack-sponsored fund. Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client may obtain many, if not all, of the funds(securities) utilized by Almanack in managing client assets independent of engaging Almanack as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Almanack’s initial and ongoing investment advisory services. In addition to Almanack’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Cash Positions: At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Almanack may increase or maintain higher cash positions. Absent a specific written agreement to the contrary, cash positions (i.e. cash, money markets, etc.) are generally included as part of assets under management for purposes of calculating Almanack’s advisory fee. Portfolio Activity: Almanack has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Almanack will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Almanack determines that changes to a client’s portfolio are neither necessary nor prudent. There can be no assurance that investment decisions made by Almanack will be profitable or result in any specific performance level(s). Clients pay Almanack advisory fees regardless of whether or not their account increases or decreases in value. Fee Differentials: As discussed above and indicated below at Item 5, Almanack shall generally price our advisory services based upon various objective and subjective factors. As a result, our clients could pay diverse fees based upon the market value of their assets, the complexity of the engagement, and the level and scope of the overall investment advisory services to be rendered, and client negotiations. As a result of these factors, similarly situated clients could pay different fees, and the services provided by Almanack to any particular client could be available from other advisers at lower, or greater, cost. Before engaging Almanack to provide investment advisory services, clients are required to enter into a discretionary or non-discretionary IMA, setting forth the terms and conditions of the engagement (including termination), which includes the fees and services to be provided. Non-Discretionary Accounts Service Limitations: Clients that engage Almanack on a non- discretionary basis acknowledge that Almanack cannot effect any account transactions without first obtaining consent to such transaction(s) from the client directly. In the event Almanack would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Almanack would be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. As a result, recommended trades for non-discretionary accounts will be delayed and, in some cases, may not be executed at all. Independent Managers: Almanack may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to- day responsibility for the active discretionary management of the allocated assets. Almanack will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. The factors Almanack considers in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, Almanack’s advisory fee as set forth in the fee schedule at Item 5 below and which will be disclosed to the client before entering into the Independent Manager engagement and/or subject to the terms and conditions of a separate agreement between the client and the Independent Manager(s). Sub-Advisory Engagements. Almanack may also serve as a sub-adviser to unaffiliated registered investment advisers per the terms and conditions of a written Sub-Advisory Agreement. With respect to its sub-advisory services, the unaffiliated investment advisers that engage Almanack’s sub-advisory services maintain both the initial and ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of client suitability for Almanack’s designated investment strategies and or programs. If the custodian/broker-dealer is determined by the unaffiliated investment adviser, Almanack will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by Almanack. Higher transaction costs adversely impact account performance. Inverse/Enhanced Market Strategies: Almanack may utilize long and short mutual funds and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. Furthermore, Almanack may hold these positions for longer than the one day that many fund prospectuses suggest, which may lead to additional risks. For periods longer than a single day, these funds will lose money when the level of the underlying indices are flat, and it is possible that the funds will lose money even if the level of the indices either increase or decrease (if inverse). Longer holding periods, higher index volatility, inverse exposure, and levered exposure each exacerbate the impact of compounding on an investor’s returns. During periods of high index volatility, the volatility of the indices may affect the returns of the funds as much as, or more. than the return of the indices. In light of these enhanced risks/rewards, a client may direct Almanack, in writing, not to employ any or all such strategies for his/her/their/its accounts. Use of Affiliated Funds and Two Levels of Fees: Affiliated Adviser and Exchange Traded Funds. Almanack’s related adviser, Gadsden LLC, (“Gadsden”) is the investment manager to an exchange- traded fund (“Affiliated Fund”) known as the Gadsden Dynamic Multi-Asset ETF (NYSE Arca: GDMA). The Affiliated Fund is managed by a principal(s) of Almanack and is used to construct many of Almanack’s model portfolios (and the Advisor accounts of clients following each model), subject to the quantitative and qualitative investment selection and evaluation criteria described in Item 8 below. The allocation of an Affiliated Fund investment included in the Advisor account will vary depending on the model portfolio selected by the client. Given the discretionary nature of the models, at a future date, the allocation of an Affiliated Fund investment in accounts will fluctuate higher or lower in a portfolio without notice to the client. An investment proposal which you may receive at the time of account investment sets forth the initial anticipated asset allocation and lists the corresponding specific investments, including the Affiliated Fund, to be used in the management of your account. Please note that both the allocation and the specific investments used for your account are subject to change. You should refer to your account statements and account information on the custodian statements, which show the composition of your account holdings and specific percentage allocation to each investment in your account, including the Affiliated Fund. Almanack and its affiliate have a conflict of interest in selecting the Affiliated Fund for client portfolios because Almanack’s affiliate earns compensation for advisory services provided to the Affiliated Fund. This compensation is in addition to the asset-based fee that you pay to Almanack resulting in the receipt of “two levels of fees.” Almanack addresses the conflict associated with investing accounts in the Affiliated Fund in multiple ways, including disclosing the conflict of interest in this Disclosure Brochure and providing you with detailed information about your account’s allocation to individual positions. These additional fees may be significant, both in absolute dollar amounts and relative to Almanack’s net income, and the receipt and retention by Almanack and its affiliate of these fees create an incentive for Almanack to select and continue to retain an Affiliated Fund over unaffiliated funds. A more detailed discussion on the additional fees that Almanack and its affiliates receive from the use of an Affiliated Fund in accounts and the ways we address this conflict of interest appear in this Item 4 and in Item 8 below. As described above under “Use of Affiliated Funds and Two Levels of Fees” in this Item 4, Almanack’s affiliate receives compensation for advisory services it provides to an Affiliated Fund. Such fund-related compensation will be in addition to the account Fee and presents a conflict of interest. You should consider this additional fund-related compensation when evaluating the amount and appropriateness of the fees we earn in connection with your account. Client Obligations: In performing its services, Almanack shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Almanack if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Almanack’s previous recommendations and/or services. Disclosure Statement: A copy of Almanack’s written disclosure statement as set forth on Part 2 of Form ADV and Form CRS shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Management Agreement and/or Financial Planning and Consulting Agreement. C. Almanack shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Almanack shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Almanack’s services. D. Almanack does not participate in any wrap fee programs. E. As of December 31, 2023, Almanack had approximately $802,193,139 in regulatory assets under management, of which $755,180,420 was managed on a discretionary basis and $47,012,720 on a non- discretionary basis. Additionally, Almanack had approximately $1,244,518,974 in assets under advisement.