A. Description of the Advisory Firm This Brochure relates to the investment advisory services offered by 55I, LLC d/b/a 55ip (“55ip” or the “Adviser”). 55ip is registered with the United States Securities and Exchange Commission (“SEC”) as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). 55ip, together with Bear Stearns Asset Management Inc., Campbell Global, LLC, Highbridge Capital Management, LLC, J.P. Morgan Alternative Asset Management, Inc., JPMorgan Asset Management (Asia Pacific) Limited, JPMorgan Asset Management (UK) Limited, JPMorgan Funds Limited, J.P. Morgan Investment Management Inc. (“JPMIM”), Security Capital Research & Management Incorporated, each an SEC registered investment adviser, various affiliated foreign investment advisers and the asset management division of JPMorgan Chase Bank, N.A. comprise the Asset Management ("AM") business of J.P. Morgan Asset & Wealth Management (“JPMAWM”). J.P. Morgan Asset Management ("JPMAM") is the marketing name for the AM businesses of JPMorgan Chase & Co. and its affiliates worldwide ("JPMC"). JPMC is a publicly traded global financial services firm. 55 Institutional Partners, LLC, which is a subsidiary of JPMC, owns 100% of the common stock of 55ip. 55ip is a Delaware limited liability company formed on June 28, 2016. B. Types of Advisory Services 55ip primarily offers the following types of discretionary and non-discretionary advisory services to its clients (collectively, the “Clients”, each a “Client”):
• Sub-advisory services are offered to affiliated and unaffiliated institutions including other registered investment advisers (“RIAs”) (each a “Sub-Advisory Client”), including advisory services through wrap fee programs as well as the Tax-Smart Active (e.g., Large Cap Leaders strategy) and Tax-Smart Index strategies where 55ip is delegated certain authority;
• Trade list delivery services are offered to affiliated and unaffiliated institutions, including RIAs (each a “Trade List Client”). 55ip provides advisory services pursuant to each Client’s investment advisory agreement, sub- advisory agreement, or trade list delivery services agreement with 55ip or its affiliates (each, an “Agreement”). These services typically include buy and sell trade recommendations to its clients at the individual account level, pursuant to the applicable agreement. Further, in addition to the services described in this section, 55ip may provide in limited instances additional services or customizations to existing services which are detailed in the applicable agreement. 55ip provides an online investment strategy engine (the “55ip Services Portal”) where Clients can access model portfolios and select tax management services. Each Client directs 55ip to utilize one or more model portfolios comprised of mutual funds, exchange traded funds (“ETFs”), and/or stocks (“Models”) pursuant to their specifications. 55ip does not create the Models; instead, the Models are provided by affiliated and unaffiliated investment advisers (“Model Providers”), as well as certain Clients who choose to use their own Models in certain circumstances ("Client-provided Models"). Models include specific securities (including share classes) and allocation weightings established by the Model Provider or Client. In certain instances Sub-Advisory Clients can work directly with a Model Provider, including 55ip's affiliate JPMIM, to customize a Model. Certain Model Providers also offer various Models to correspond to different risk profiles. Clients can then select the Model that best fits their risk profile needs. Generally, Models include both the Model Provider's proprietary Funds (as defined in Item 8.A) as well as third-party Funds; however, Models provided by JPMIM, are generally comprised of either 100% mutual funds and ETFs managed by JPMIM or its affiliates (“JPMorgan Affiliated Funds") or a very significant percentage of JPMorgan Affiliated Funds, subject to JPMIM's program parameters. 55ip is not responsible for selecting the funds within a Model provided by a Model Provider. Information pertaining to selected Models, including brochures, fact sheets, commentaries and other documents produced by Model Providers, is also available through the 55ip Services Portal. 55ip's services are offered through the use of 55ip's proprietary technology which incorporates a tax management technique referred to as "tax loss harvesting" that is primarily used in the following ways: "Tax-Smart Transitioning", "Ongoing Tax Management", and "Tax-Smart Withdrawals". See Item 8.A, Methods of Analysis, for more information regarding these tax management techniques. 55ip's services also include ongoing trading and rebalancing services, which generally accommodate cash management, periodic rebalancing and investment changes at a frequency agreed upon by 55ip and the Client. Client-provided Models are assessed for rebalancing typically on a monthly basis. Models provided by Model Providers are typically assessed for rebalancing when the Model Provider communicates an updated Model allocation to 55ip (e.g., quarterly), based on negotiated terms within the agreements between 55ip and the Model Provider. Notwithstanding the rebalancing frequency, other trades may occur in accounts outside of the rebalancing frequency related to tax loss harvesting or to accommodate cash management withdrawal/deposits. Sub-Advisory Clients When 55ip is engaged to provide discretionary services to its Sub-Advisory Clients, 55ip creates the buy and sell orders and directs trading activity for the individual accounts, pursuant to a sub- advisory Agreement. 55ip does not directly maintain a relationship with underlying investors of its Sub-Advisory Clients. Furthermore, 55ip does not serve as an investment adviser to underlying investors of its Sub-Advisory Clients, except in Wrap Programs. Tax-Smart Active and Tax-Smart Index strategies (collectively "Tax-Smart Strategies"): 55ip also provides non-discretionary sub-advisory services on behalf of its affiliate, JPMIM, who is acting as a portfolio manager for separately managed account programs, including Wrap Programs. In this program, JPMIM reviews trade orders and chooses whether to implement such trades in JPMIM's underlying investors’ accounts. In this context, JPMIM’s Models consist of stocks and ETFs. For some of these Models, such as the Tax-Smart Index strategies, instead of providing a Model with specific securities and allocation weightings, JPMIM provides the investment guidelines for the strategy and 55ip utilizes proprietary technology guided by structured, mathematical, and rules-based methodologies to implement client portfolios. In this program, 55ip does not directly maintain a relationship with, nor serve as an investment adviser to any underlying investor of its Sub-Advisory Clients. Additional information for those invested in the Tax-Smart Active and Tax-Smart Index strategies within the Pershing Managed Connect program: Due to operational constraints of the platform, your respective account application (or other similar custodial agreement) with Pershing indicates 55ip as the

investment adviser of this strategy. However, as described herein, JPMIM is in fact the investment adviser for this strategy and delegates certain tax overlay and implementation responsibilities to 55ip, its affiliate. See JPMIM's Form ADV Part 2A at www.adviserinfo.sec.gov for more information regarding the Tax-Smart Active and Tax-Smart Index strategies. Trade List Clients When 55ip is engaged to provide non-discretionary trade list delivery services, 55ip provides buy and sell recommendations to its Trade List Clients at the individual account level, pursuant to a Trade List Delivery Services Agreement. The Trade List Clients then choose when and whether to execute such trades in their underlying investors’ accounts. 55ip does not maintain a direct relationship with, nor serve as an investment adviser to any underlying investor of its Trade List Clients. C. Client Tailored Services and Client Imposed Restrictions Certain investment services may be tailored for each Client’s specific needs and objectives. The Adviser typically makes investments for Clients in accordance with the guidelines associated with each of the Models and determined by the Model Providers (the “Model Guidelines”). Custom Model services are also available in certain instances where Clients can work directly with a Model Provider to customize a Model. The Adviser has controls to monitor compliance with each Model Provider’s Model Guidelines. For taxable accounts, Clients can select tax transition and/or tax management services, where the Adviser may deviate from Model Guidelines to account for these specific considerations. For more information about custom Models, see Item 4.B, Types of Advisory Services. When providing services on behalf of its affiliate, JPMIM, as described above (e.g., the Tax-Smart Active and Tax-Smart Index strategies), Clients can request reasonable restrictions on the management of their accounts, subject to JPMIM's acceptance and the program’s parameters. These restrictions can include certain industries, sectors or specific securities, as available through the 55ip Services Portal. Certain restriction categories include criteria derived from an affiliate. D. Wrap Fee Programs The Adviser’s sub-advisory services are also available through bundled wrap fee programs ("Wrap" or "Wrap Programs") sponsored by certain broker-dealers or investment advisers ("Sponsors"). A client in a Wrap Program typically receives professional investment management of account assets through one or more investment advisers participating in the program. Except for execution charges for certain transactions as described below, clients pay a single, all-inclusive (or "wrap") fee charged by the Sponsor based on the value of the client’s account assets for asset management, transactions effected by the Sponsor, custody, performance monitoring and reporting through the Sponsor. The Adviser receives a portion of this wrap fee for its investment management services. The Sponsor typically assists the client in defining the client’s investment objectives based on information provided by the client, aids in the selection of one or more investment advisers to manage the client’s account, and periodically contacts the client to ascertain whether there have been any changes in the client’s financial circumstances or objectives that warrant a change in the management of the client’s assets. In certain Wrap Programs, the Sponsor contracts with other investment advisers to perform these services. The Sponsor typically pays the Adviser a fee based on the assets of clients invested in the applicable strategy in the Wrap Program. The Adviser also manages client assets in unbundled advisory programs. Wrap clients should be aware that comparable services may be available at lower aggregate costs on an unbundled basis through the Sponsor or through other firms. In such cases, fees are unbundled for various services and negotiated separately by the client including, but not limited to, investment management, custody and trade execution, although the Adviser’s fee covers only investment management services and not custody and brokerage services. Depending on the circumstances, the aggregate of any separately paid fees may be lower (or higher) than the wrap fee charged in the Wrap Program. Payment of a bundled asset-based wrap fee may or may not produce accounting, bookkeeping, or income tax results better than those resulting from the separate payment of (i) securities commissions and other execution costs on a trade-by-trade basis and (ii) advisory fees. Wrap accounts are generally managed in the same or similar manner to other Sub-Advisory Client accounts. However, Wrap Programs may impose specific restrictions and investment guidelines that are more restrictive than other accounts; this is discussed in the Sponsor’s Form ADV brochure. See the Sponsor's Form ADV brochure for more information. For additional information regarding Fees and Compensation, Brokerage Practices and Custody, please see Items 5.A-E, Item 12, and Item 15, respectively. Please refer to Schedule D in Part 1A of 55ip’s Form ADV for a full list of the Wrap Programs in which 55ip participates. Trading Away Practices for Wrap Program Accounts The Adviser may place a Wrap Program Client's trade with a broker-dealer other than the Sponsor (or the Sponsor’s designated broker-dealer) if it determines that using another broker-dealer would meet its best execution obligations to Clients. This practice is frequently referred to as "trading away". Trading away from the Sponsor will usually result in the imposition of a commission or equivalent fee on the trade or other charges, including but not limited to foreign currency conversion fees, American Depositary Receipts ("ADRs") fees, and foreign tax charges, as well as fees embedded in the price of the security being bought or sold, such as a mark-up or mark-down. Such fees are paid by the Client and are in addition to the wrap fee. If the Adviser trades away from the Sponsor to effect an agency trade for a Wrap Program account, Clients should expect that any execution costs charged by that other broker-dealer will be charged to the Wrap Program account. In certain circumstances, transactions may be effected by that other broker-dealer on a principal basis and therefore the spread, mark-ups and mark-downs will be paid by the account on those trades to the third-party broker-dealer. As noted above, such execution costs are in addition to the wrap fee paid by Clients. For a discussion of order aggregation with respect to Wrap Program accounts, see Item 12.B, Order Aggregation. E. Amounts Under Management As of February 29, 2024, 55ip had assets under management in the amounts set forth below: AssetsUnderManagement U.S.DollarAmount Assets Managed on a Discretionary Basis $19,484,140,392 Assets Managed on a Non-Discretionary Basis $0 TotalRegulatory AssetsUnderManagement $19,484,140,392 Other Advisory Assets not included in Regulatory Assets Under Management* $12,551,876,398 TotalAssetsUnderManagement $32,036,016,790 *This category includes Trade List Delivery Services and Tax-Smart Strategies.