INTRODUCTION Cabana LLC d/b/a Cabana Asset Management (hereinafter “Cabana” “we” or the “firm”) is a registered investment adviser (“RIA”) based in Fayetteville, Arkansas. We are a limited liability company organized under the laws of the State of Arkansas. Cabana is a wholly owned subsidiary of The Cabana Group, LLC, a Delaware limited liability company. CI Financial Corp. (symbol: TSX: CIX; NYSE: CIXX), owns 49% of the Cabana Group through its subsidiaries CI Private Wealth US, LLC, CI US, LLC, and CI US Holdings, Inc., and five other entities controlled by employees, affiliates, or investment adviser representatives of Cabana own the other 51% of the Cabana Group. Cabana has provided investment advisory services since 2007. Cabana’s day-to-day operations are managed by (1) G. Chadd Mason, CEO and Co-Founder; (2) Louis Shaff, CFO and Co-Founder; (3) Christopher L. Carns, COO; and (4) Albert Moore, CCO. As used in this Brochure, the term “Associated Person” refers to anyone who is an officer or employee of Cabana and all individuals providing investment advice on Cabana’s behalf. Cabana LLC offers investment advisory and money management services to individual clients and businesses (either through traditional investment management or through qualified retirement plans), other registered investment advisers, and institutional clients. Cabana developed a proprietary algorithm, “CARA” (Cyclical Asset Reallocation Algorithm) for risk management, which seeks to reduce volatility and exposure to down markets by evaluating economic and technical market conditions and allocating to assets that are deemed attractive in the current market. CARA is utilized in all of Cabana’s investment solutions, which include Target Drawdown Professional Series SMAs (Separately Managed Accounts), Legacy Target Drawdown Professional Series SMAs (Separately Managed Accounts), Target Drawdown ETFs (Exchange Traded Funds), Target Drawdown CITs (Collective Investment Trusts), Target Leading Sector ETFs, Cabana Income SMA, and Cabana Black (a hedge fund offering). All “Target Drawdown” strategies numerically quantify acceptable levels of risk by identifying a “target drawdown” percentage at the onset of the investment process. They are constructed with the primary goal of avoiding or minimizing losses where possible, and especially losses that exceed the applicable target drawdown parameter of each model. We believe this investment philosophy allows clients to remain fully invested at all times, to set expectations for loss, and to actively participate in favorable market conditions. All Target Drawdown products are derivatives of the same model but are constructed by adjusting holdings and the drawdown parameters to the desired volatility range. Cabana offers multiple drawdown variations to meet the needs of investors across risk profiles. Target drawdown percentages range from 5-16% (including Cabana Black). Cabana LLC claims compliance with the Global Investment Performance Standards (GIPS®). Cabana LLC has been independently verified on a firm-wide basis for the period January 1, 2012, to December 31, 2022 (next examination is currently in progress). GIPS® is a trademark of the CFA Institute. The CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein. To receive a GIPS Report or a firm’s list of composite/pooled fund descriptions, please email the request to info@thecabanagroup.com. In addition to the traditional investment advisory and financial services that we provide, our firm was founded by attorneys, and we currently have licensed attorneys on staff who operate Cabana Law Group, in the state of Arkansas, and Prevost, Shaff, Mason and Carns, PLLC in the state of Texas. Cabana Law Group combines more than 75 years of legal practice in estate planning, business succession planning, asset protection, corporate law, and real estate transactions. Some of our Associated Persons also act as insurance agents independent of Cabana’s investment advisory services. When they provide fixed insurance products or services, they act through one of Cabana’s affiliates. The types of services we provide clients are described in more detail below. SERVICES Portfolio Management Services for Cabana’s Individual Retail Clients Our firm offers primarily discretionary portfolio management services to our clients based on their chosen asset allocation guidelines, risk tolerance, and investment objectives. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in a client’s account without contacting them. Our discretionary services are generally limited to the management of Cabana’s Target Drawdown Professional Series and Legacy Target Drawdown Professional Series Models. All of Cabana’s individual retail clients’ assets are held in the form of separately managed accounts and are maintained at a qualified Custodian. We also offer non-discretionary portfolio management services, which means that we must obtain your approval prior to placing any trades in your account. The Target Drawdown Professional Series and the Target Leading Sector series both invest in a combination of third-party ETFs and also ETFs where Cabana acts as the subadvisor, which currently are the Cabana Target Drawdown ETFs and Cabana Target Leading Sector ETFs (“Cabana ETFs”) that Cabana manages via a sub-advisory agreement with Exchange Traded Concepts (“ETC”), the ETF provider. Cabana’s management fee set forth in the investment advisory agreement between Cabana and its clients, as applicable, will be offset (and reduced) each month by an amount equal to the management/sub- advisory fees received by Cabana from ETC for the Cabana ETFs, for the prior month with respect to each clients’ investment in the Cabana ETFs. Detailed information regarding Cabana’s ETFs can be found in the offering documents, which are available at https://thecabanagroup.com/etf-prospectus/. The Legacy Target Drawdown Professional Series is the original of Cabana’s Target Drawdown SMA products and was the primary SMA offering prior to September 17, 2020, when Cabana’s Target Drawdown ETFs were released. The Legacy portfolios are still utilized for some client accounts. The Legacy Model SMAs differ from Cabana’s Target Drawdown Professional Series in that proprietary Cabana ETFs are not used. Our investment advice is tailored to meet our clients’ needs and investment objectives. Separate account clients can impose reasonable restrictions on the firm’s management of their accounts, subject to our acceptance of those restrictions. Based on each client’s specific financial situation and goals, clients will generally be invested in one of Cabana’s Target Drawdown Professional Series Portfolios or may also hold other securities positions. Cabana generally builds portfolios that put target drawdown limits at the forefront. Drawdown is defined as the maximum loss, or amount an investment can be expected to fall (these a r e t a r g e t s , n o t g u a r a n t e e s ), f r o m p e a k t o t r o u g h d u r i n g a d v e r s e m a r k e t conditions. Cabana’s Target Drawdown Professional Portfolios are constructed using an algorithm that Cabana operates, which we refer to by the acronym CARA, which seeks to monitor economic and technical market conditions to identify assets that are particularly attractive at a given time in the business cycle. All Target Drawdown Professional Portfolios strive to limit losses that exceed investor risk tolerance in down markets, while still participating in up markets. Cabana’s Target Drawdown Professional Series Portfolios are primarily invested in various index- based and sector-based Exchange Traded Funds (ETFs), including the Cabana ETFs, that have a history of making dividend payments. In certain instances, we may also invest a portion of a client’s account in mutual funds. Cabana

monitors the portfolio performance daily, rebalancing the portfolios whenever necessary as changes occur in market conditions and as dictated by CARA. Financial Planning Services for Cabana’s Individual Retail Clients We offer broad-based financial planning for clients seeking this service, including a variety of services, mainly advisory in nature, regarding management of financial resources. Our advice is based upon an analysis of the client’s individual needs and begins with an initial complimentary consultation. Once we collect and analyze all documentation, we provide a written financial plan designed to achieve the client’s financial goals and objectives. In this way, Cabana seeks to assist the client in developing a strategy for the successful management of income, assets, and liabilities. In general, financial planning services can include any one or all of the following:
• Cash Flow Analysis – Assessment of a client’s present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements, etc. Cabana advises on ways to reduce risk, and to coordinate and organize records and estate information.
• Retirement Analysis – Identification of a client’s long-term financial and personal goals and objectives includes advice for accumulating wealth for retirement income or appropriate distribution of assets following retirement. Tax consequences and implications are identified and evaluated.
• Insurance Analysis – Includes risk management associated with advisory recommendations based on a combination of insurance types to meet a client’s needs, e.g., life, health, disability, and long- term care insurance. This will necessitate an analysis of cash needs of family at death, income needs of surviving dependents, and disability income analysis.
• Portfolio Analysis/Investment Planning – We provide investment alternatives, including asset allocation, and effect on a client’s portfolio. We evaluate characteristics of existing investments as well as their suitability for a client’s objectives.
• Education Savings Analysis – Alternatives and strategies for the complete or partial funding of college or other post-secondary education.
• Estate Analysis – We provide advice with respect to property ownership, distribution strategies, estate tax considerations, and tax payment techniques. The recommendations and solutions are designed to help the client to achieve their desired goals. Financial plans are created based on the financial information provided to us by the Client. We should be notified promptly of any changes to a client’s financial situation, goals, objectives, or needs. Clients may choose to accept or reject our recommendations. If clients decide to proceed with our recommendations, they may do so either through our investment advisory services or by using the advisory/brokerage firm of their choice. Private Fund Investments Interests in Cabana’s private fund (Cabana Black) is privately offered only to accredited investors pursuant to exemptions available under the Securities Act of 1933, as amended (the “Securities Act”), and the regulations promulgated thereunder. The fund is not registered with the SEC. Typically, interests are offered to high net worth individuals and institutional investors. Employees of Cabana and its affiliates, and other qualified individuals also may invest in this fund. The fund is managed by Cabana’s affiliate, Cabana Black, LLC. Portfolio Management Services for Investment Platform, Signal Provider Relationship and Sub- Advisory Clients Model Provider Services: Our firm offers the Target Drawdown Professional Series to investment platforms managed by third parties, and third-party investment advisers can license our portfolios for use with their clients. The recommendations in the model portfolios generally reflect recommendations we are making to our own discretionary clients. We may have begun trading for our own discretionary client accounts before the third-party investment adviser has received or had the opportunity to review or implement the model portfolio updates. This means that the third-party investment adviser’s clients may receive a better or worse price for a security than that our clients pay, especially with large orders or where the securities are thinly traded. We do not control third-party investment adviser’s trading or the market impact of its trades to the same extent that we can, for our own discretionary client accounts. We are not responsible for overseeing the provision of services by a model-based program sponsor, or the fees charged by such an entity, and cannot assure the quality of its services. Sub-Advisory Services: Cabana manages the Cabana ETFs on a discretionary basis via a sub-advisory agreement with Exchange Traded Concepts (“ETC”), the ETF provider. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in those accounts without contacting the adviser or client. Our firm may also act, from time to time, as third-party advisor or sub-advisor on accounts held by other registered investment advisers (and their qualified custodians), giving us the ability to implement our Target Drawdown Professional Portfolios on behalf of those advisers’ clients. We may operate in this capacity on the custodial platforms of TD Ameritrade, Interactive Brokers, Charles Schwab and Fidelity Investments ( together, o u r “ Custodians”) primarily v i a t h e GeoWealth Platform T u r n k e y A s s e t M a n a g e m e n t P l a t f o r m . Retirement Plan Services Cabana Target Drawdown CITs. Cabana manages the Cabana Collective Investment Trust (“CITs”) for certain assets subject to the Employee Retirement Income Security Act of 1974, as amended, (“ERISA”). Specifically, Cabana has been appointed as Investment Manager to the CITs (as that term is defined under ERISA) by the Trustee of the CITs. The CITs are bank-maintained and not registered with the SEC under the Securities Act of 1933, as amended or applicable securities laws of any state or other jurisdiction. The CITs are not mutual funds registered under the Investment Company Act of 1940, as amended, (“1940 Act”) or other applicable law, and unit holders are not entitled to the protections of the 1940 Act. The regulations applicable to the CITs are different from those applicable to a mutual fund. Employee Education Services. We may provide employee education services by conducting meetings with employers and employees for a group, or on an individual basis, and the meetings can be conducted either on site or via teleconferencing. We may also conduct employee surveys to determine interest in specific topics and provide other communication services to employees regarding investment education. Finally, we may assist employees with enrollment and re-enrollments in the Plan. Unless otherwise stated, the retirement plan services are not investment advisory services or investment advice as defined under ERISA. Retirement plan services are offered through third parties, as follows: 1) customized retirement planning through O’Connell Pension and Consulting; 2) platform sponsored by BidMoni, Inc., along with Comprehensive Consulting Group and American Trust Company; and 3) Turnkey Cabana PEP Solutions with access to LeafHouse Financial Advisors, LLC and BlueLeaf Wealth, Inc. Clients should promptly notify Cabana or their respective advisor (for sub-advisory clients) if there is ever any change in their financial situation or investment objectives to ensure that the proper risk tolerance, investment objectives, and recommendations are reflected on their account. Clients should also check their account balance by reviewing their monthly statement from their qualified Custodian. Contact your advisor if you do not receive a monthly custodial statement. ASSETS UNDER MANAGEMENT As of December 31, 2022, Cabana had approximately $1,471,439,448 in discretionary regulatory assets under management