Banyan Global Investment Advisors, LLC (“BGIA”, “we”, “us”, “our”, or “the firm”), a Delaware limited liability company, was formed in 2011 but did not commence operations until 2012. In 2015, we became a Florida limited liability company. Daniel Reich is our sole managing member and owns 100% membership interests of BGIA. We provide asset management services to clients (“Clients”) through separately managed account arrangements (“Client Accounts” or “Accounts”). Our typical client (or client family) has a minimum of 1 million dollars in investable assets. Charles Schwab and Company (“Schwab”) is our preferred custodian and the majority of our clients maintain their assets there. Please see Item 7, “Types of Clients” for information on the types of Clients that BGIA services. BGIA manages Client Accounts on an individual basis and determines to which accounts specific investment opportunities should be allocated. BGIA, as a matter of practice, makes investment opportunities available to all Clients who are eligible to participate and where the investment opportunities are deemed by us to be appropriate for the specific Client, as outlined on the client’s Investment Policy Statement (“IPS”). Factors we generally consider in allocating opportunities include the Client’s:
• Investment objectives;
• Investment restrictions;
• Risk tolerance, as determined by BGIA in coordination with the Client; and
• Cash availability. In addition, “Proprietary Accounts” (those accounts of firm members/employees and affiliates, including joint accounts with their immediate families) may trade separately in securities not offered to other Clients after BGIA has determined that the investment is not eligible, not suitable and/or not appropriate for other Client Accounts. Please see Item 8, “Methods of Analysis, Investment Strategies and Risk of Loss,” Item 11, “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” and Item 14, “Client Referrals and Other Compensation” for additional information regarding conflicts of interest associated with Proprietary Accounts. While we will, if requested, provide fully customized portfolio management services within the characteristics set by a Client, some of BGIA’s Clients engage the firm to protect principal while providing a reasonable rate of return by building customized portfolios primarily using municipal bonds. BGIA may use other security types in augmenting these municipal bond portfolios that generally have a yield component such as equities, master limited partnerships, business development companies, exchange-traded funds (ETFs), mutual funds, closed-end funds, corporate bonds, preferred securities, and mortgaged-backed securities. BGIA will on occasion engage, with the client’s approval and authorization, a third-party manager. This is done through a Separately Managed Account (SMA) at Schwab, where the manager has limited power of attorney to trade a specific asset class within that account and withdraw its agreed fee. The third- party manager may compensate BGIA as part of that fee. If BGIA is compensated by the third- party manager, BGIA will not charge the client any additional fees on the SMA. BGIA and the third-party manager must disclose to the client the fee sharing arrangement. In addition, certain high net worth individuals engage BGIA to manage customized portfolios on their behalf. Clients who engage us for such customized investment strategies are highly sophisticated in financial matters and engage BGIA to execute customized, often complex, investment strategies particular to the sophisticated Client. While such Clients provide discretionary authority to BGIA, in practice these Clients are typically actively involved in managing these sophisticated investment portfolios and in directing the execution of trades. We also engage in the following activities on behalf of Clients: Equity Initial Public Offerings (“IPOs”) While BGIA does not advise Clients to purchase equity IPOs, upon request we will assist a Client desiring to participate in an equity IPO by submitting an indication of interest for the shares. In general, we expect investments in IPOs to be appropriate only for those Clients who: 1. Have a minimum of $2 million invested with BGIA; 2. Understand the potential risks associated with these investments; and 3. Are able to absorb potential losses which may result and acknowledge as such. Investing in IPOs carries significant risks, and Clients should exercise caution in participating in IPOs. We do not advise Clients on such purchases. All Clients participating in IPOs are required to affirm such investments are suitable for the client on the IPS. Other Limited Offerings - Fixed Income New Issues and Equity Secondary Offerings The firm may engage in what is considered high risk, high frequency trading in Fixed Income New Issues and Equity Secondary Offerings (“Other Limited Offerings”) on behalf of certain highly sophisticated Clients. The objective of such trades is to generate trading activity with outside broker-dealers, which we believe provides us with a competitive advantage in accessing municipal fixed income securities for our core Client Accounts. In other words, we believe the commissions generated on these trades improves our relationship with the broker-dealers and provide an opportunity for us to access fixed income municipal securities for our Client Accounts, which the firm may otherwise not be able to access. From time to time a secondary offering may occur in a security held by accounts not qualified to participate in Other Limited Offerings. BGIA considers trading in Other Limited Offerings to be high risk and only engages in this activity on behalf of Clients who acknowledge, in writing, their desire

to participate in Other Limited Offerings and their acceptance of the inherent risks associated with purchasing Other Limited Offerings within the IPS. The IPS will document the rationale for considering a Client eligible to transact in Other Limited Offerings, which includes Clients who: 1. Have a minimum of $2 million invested with BGIA; 2. Are considered highly sophisticated and experienced in the financial markets and can be reasonably expected to understand the inherent risks of this high volume, high frequency transactions; and 3. Are able to absorb potential losses which may result and acknowledge as such. In an effort to be fair and balanced, BGIA maintains an Investment Aggregation and Allocation Policy to address conflicts of interest related to Proprietary Accounts. We describe these options further, including the related risks of loss, under Item 8, “Methods of Analysis, Investment Strategies and Risk of Loss.” Prior to engaging us to provide investment management services, our Clients enter into formal investment management agreements with us setting forth the terms and conditions under which we will manage the Client Account, as well as one or more separate custodial/clearing agreements with designated broker-dealer or bank custodians. The investment management agreement continues in effect until terminated by either party by written notice in accordance with the agreement’s terms. Sub-Advisory Arrangements In addition to the programs described above, we have independently entered into sub-advisory agreements with unaffiliated registered investment advisors (“sub-advisor”) whereby the sub- advisor will manage certain designated assets in client portfolios (each a “Designated Portfolio” and collectively, the “Designated Portfolios”). Depending on the sub-adviser, we will either engage them directly or you will be required to enter into a separate agreement with the sub- advisor that defines the terms in which the sub-advisor will provide its services. Any recommendations made by the sub-advisor shall be made on a discretionary basis subject only to the investment objectives and restrictions we imposed by written notice to the sub- advisor. Prior to engaging the services of the sub-advisor, we will consult with you and determine your financial situation and individual needs, including, without limitation, your investment objectives and restrictions. In addition, we will perform initial and ongoing oversight and due diligence over each sub-advisor to ensure the strategy remains aligned with your investment objectives and overall best interest. It is, however, your obligation to notify the sub- advisor in writing of any changes in your financial situation. A complete description of the third- party investment advisor’s services and compensation relating to this arrangement will be disclosed in the sub-advisor’s Form ADV Part 2 which will be provided to you at the time an agreement for services is executed and an account is established. We serve as your primary advisor and relationship manager. Your IAR will be available to answer questions you may have regarding the portion of your account managed by the sub- advisor and will act as the communication conduit between you and the sub-advisor. The sub- advisor may take discretionary authority to determine the securities to be purchased and sold for your account. However, we will direct the sub-advisor of the custodian in which to effect all transactions. IRA Rollover Recommendations For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with client interests. We operate under an exemption that requires we act in the clients’ best interest and not put our or our employees’ interests ahead of the clients. Under this exemption, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that we and our employees give advice that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when our and our employees believe it is in the clients’ best interest. As of December 2023, we managed in excess of US$168,181,354 in regulatory assets under management (“RAUM”) all on a non-discretionary basis. However, certain highly sophisticated clients choose to take a very active role with the management of their accounts. We, while still retaining discretionary authority over the account, will strive to accommodate the level of involvement a client desires in the day-to-day management of their account. A number of our clients maintain accounts away from Schwab for which we may, at the client’s direction, purchase or sell securities. We have not included any of the value of those other accounts in calculating our RAUM.