Eton, ADV Part 2A. Page 7 of 24 4(B) Eton’s Advisory Services In this section, we describe the services we offer as well as the fees that correspond to those services. Service: Wealth Management and Family Office Services Service description: We offer holistic wealth structuring, family office and investment consulting services to ultra high net worth individuals, families, the businesses they serve, institutions and charitable organizations. We offer our clients comprehensive financial planning, including estate transfer and tax planning, gifting and philanthropic strategies and cash flow forecasting. Our family office (“FO”) services include, but are not limited to, the following.
• Bill Payment & Budgeting
• Cash Flow Management
• Client Education
• Estate Planning
• Family Governance
• Family Meeting Coordination
• Financial Planning
• Insurance Review & Coordination
• Tax Planning We provide customized, discretionary and non-discretionary portfolio management using a “manager of managers” approach, including “Outsourced Chief Investment Officer” services to institutional clients. Eton Advisors will act solely in our capacity as a registered investment adviser and does not provide any legal, accounting or tax advice. You should seek the counsel of a qualified accountant and/or attorney when necessary. As part of our advisory services, we may assist clients with tax loss harvesting and will work with the client’s tax advisor to answer any questions related to the client’s portfolio. We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). Eton is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. Eton is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, Eton is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). Eton, ADV Part 2A. Page 8 of 24 Service: Investment Manager for Pooled Investment Vehicles (Farrington Funds) Service description: We serve as the investment manager for certain private investment funds (the “the Funds”). The Funds were established to aggregate certain investment exposures, reduce investment minimums and achieve other administrative efficiencies for our advisory clients. Currently, the Funds consist of three “funds of hedge funds,” which invest in hedge funds and mutual funds; and two “liquid funds,” which invest in mutual funds and with separately managed account managers. Service: UPTIQ Treasury & Credit Solutions, LLC Service description: We offer clients the option of obtaining certain financial solutions from unaffiliated third- party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. Service Fee: At no additional cost for clients. Eton, ADV Part 2A. Page 9 of 24 4(C) Customization of Advisory Services To the fullest extent possible, we endeavor to tailor our advisory services to meet the specific needs of each and every client. In order to determine a suitable course of action for an individual client, we review our clients’ financial circumstances and other factors that influence the investment recommendations we may make to you from time to time. Such review may include, but is not necessarily limited to, investment objectives, consideration of a client’s overall financial condition, income and tax status, personal and business assets, risk profile, and other factors unique to a client’s particular circumstances. Our clients, excluding any Funds we manage on a fully discretionary basis, are free to impose restrictions or other conditions with regard to how we provide our advisory services. If we agree to such restrictions and/or

conditions, please be advised that restrictions and guidelines that you impose on our investment management functions may affect the composition and performance of custom portfolios (as a result, performance of custom portfolios within the same investment objective may differ and you should not expect that the performance of a custom portfolio will be identical to any other individual’s portfolio performance) as well as any recommendations provided to you. 4(D) Wrap Fee Program Participation None of our investment advisory services involve the use of wrap programs. 4(E) Assets Under Management (“AUM”) As of December 31, 2023, Eton managed a total of $1,961,699,026 of which $1,277,734,387 is managed on a discretionary basis and $683,964,639 on a non-discretionary basis. In addition to these assets under management, Eton advised clients on a solely investment consulting basis. We refer to these other assets as “assets under advisement.” The value of these other assets under advisement is approximately $ $134,349,885 as of December 31, 2023. For certain separately managed account clients, Eton may allocate a portion of managed assets to family limited partnerships or other vehicles (“FLPs”), which are separately advised by Eton. Since the FLP is also a client, the assets of the FLP are included when calculating RAUM. This has the practical effect of counting most of the FLP client’s assets at that vehicle level and again at the separate account level of the individual investor. Likewise, Eton may allocate a portion of the managed assets of certain clients to the private funds also managed by Eton. Since the Funds are themselves clients, the firm counts these private fund assets when calculating assets under management. This has the practical effect of counting most of the private fund’s assets at the fund level and again at the separate account level of the individual investor. Neither the FLP clients nor the Funds incur additional management fees, although Eton receives administrative costs of .08% from the Funds. More information about fees is included in Item 5, below. Eton, ADV Part 2A. Page 10 of 24 5(A) Eton Advisory Fees For our wealth management and family office services, we charge a single fee based on the value of assets we oversee. Asset-Based Fee Schedule Account(s)/Portfolio Value Annual Percentage First $5,000,000 1.00% Next $5,000,000 0.75% Next $15,000,000 0.65% Next $25,000,000 0.55% Next $25,000,000 0.45% Next $25,000,000 0.40% Over $100,000,000 0.35% For clients invested in any of the Funds we manage, such client is not charged an Wealth Management and Family Offices Services additional management fee at the Fund level in addition to the asset-based fee paid to Eton. However, the Funds incur administrative fees of .08% which are paid to Eton and bear expenses described in the offering and governing documents for the Funds. Such fees and expenses are borne by investors in Eton managed funds, and are in addition to the asset-based fees listed above. Service fees: All fee arrangements are negotiable at our sole discretion. Specific fee arrangements, including fixed flat fees, will be set forth in your Agreement with us. Fees can be waived at Eton’s discretion. Eton aggregates Relationship Assets for the purpose of determining the applicable Annual Fee Rates. Charitable accounts in a relationship are assessed the lowest annual fee rate of the relationship. Our fees are based on the market value of your assets under management, including cash, accrued interest, accrued dividends, and securities purchased on margin. Additions and Withdrawals A pro-rata fee will be charged based on the value of additional contributions over $100,000. No portion of any prepaid fees will be refunded based on the value of partial withdrawals. You understand that the services provided hereunder are designed for long- term investments and that withdrawals may impair the achievement of your investment objectives. . Fee frequency/timing: For the services described above, the frequency and timing of our fee collection process occurs as follows: ☒ quarterly, ☐ monthly, ☒ in advance, or ☐ in arrears. Specific fee arrangements will be set forth in your Agreement with us. Investment Manager for Pooled Investment Vehicles (Farrington Funds) Management fees : The Funds do not pay a separate management fee. Clients that invest in the Funds pay the relationship-based quarterly fees on all assets we oversee, including assets invested in the Funds. Neither we nor any of our affiliates are paid any “carried interest” or other form of incentive compensation based on the performance of the Funds.