A. Description of the Advisory Firm Dunhill Financial, LLC is a Limited Liability Company organized in the State of Florida. The advisory firm was formed on November 5th, 2014, and the principal owner is Brian Dunhill. Prior to the formation of the LLC, advice was given through Dunhill Financial, SPRL a Limited Liability Company organized in Belgium and formed on November 23rd, 2011. The principal owner of the Belgian company is Brian Dunhill. From October 2016 until January 2017, Dunhill Financial did business under the name of Cross Border Planning (as a DBA of Dunhill Financial). Since September 20th 2019, Dunhill Financial LLC is the sole shareholder of Dunhill Financial Ltd, a limited liability company organized in the United Kingdom, that provides financial advice to residents of the United Kingdom and Europe. B. Types of Advisory Services Dunhill Financial, LLC (hereinafter “Dunhill Financial”) offers the following advisory services: Investment Supervisory Services Dunhill Financial offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Dunhill Financial creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Dunhill Financial evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Dunhill Financial will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These services can be based on fixed fees or can be included in the annual investment fees. The final fee structure is documented in Exhibit II of the Financial Planning Agreement. Services Limited to Specific Types of Investments Dunhill Financial generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, hedge funds, REITs, insurance products including annuities, and government

securities. Dunhill Financial may use other securities as well to help diversify a portfolio when applicable. Robo-Advisory Portfolio Management Services Dunhill Financial provides “robo-advisory” portfolio management services through an online interface. This entails the use of algorithm-based portfolio management advice, rather than in-person investment advice. These automated investment solutions are customized to each client and based on individual characteristics, such as the client’s age, risk tolerance, income, and current assets, among others. Dunhill Financial’s investment advisory personnel oversee the algorithm but may not monitor each client’s account. Clients are encouraged to update their account/questionnaire with any change in their objectives, risk tolerance, or other pertinent information, as that information factors into the portfolio’s composition. C. Client Tailored Services and Client Imposed Restrictions Dunhill Financial offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Dunhill Financial from properly servicing the client account, or if the restrictions would require Dunhill Financial to deviate from its standard suite of services, Dunhill Financial reserves the right to end the relationship. Dunhill Financial provides online “hybrid robo-advisory” portfolio management. Client accounts are invested into a thematic portfolio, depending on the client’s individual objectives. Through the internet, the client interface is automated to the extent possible. The approach is "hybrid" in that the portfolio management process relies upon both algorithms and portfolio management by the portfolio manager, each designed to be utilized across multiple clients. The client’s investment profile dictates the portfolio strategies, which in turn may impose restrictions in investing in certain securities or types of securities. D. Wrap Fee Programs Dunhill Financial does not manage or sponsor a wrap fee program. D. Amounts Under Management Dunhill Financial has the following assets under management: Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $ 240,639,600.00 $ 0.00 December 2023