A. Firm Information Veery Capital, LLC dba Veery Capital is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”), which is organized as a limited liability company (“LLC”) under the laws of the State of Delaware. Veery Capital, LLC was founded in August 2018 and is owned and operated by David (Chris) Benfer (Partner and Chief Compliance Officer), Matthew J. MacNeal (Partner) Kathleen Simolike (Partner) and Cortney Milner (Partner). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Veery Capital. For questions regarding this Disclosure Brochure, please contact David (Chris) Benfer at (302) 660-3350. The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. B. Advisory Services Offered Veery Capital, LLC offers advisory services to individuals, high net worth individuals, families, trusts, estates, and businesses and retirement plans (each referred to as a “Client”). Veery Capital, LLC provides a comprehensive approach to its wealth advisory services. Services are tailored to the unique needs of each Client. Investment Management Services Veery Capital, LLC provides customized wealth management solutions for its clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and planning services. Veery Capital, LLC works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. Veery Capital, LLC customizes its investment management services for its clients. Veery Capital, LLC will implement the investment strategy with its internal management and/or the use of unaffiliated money managers or investment platforms (as described below). Internal Investment Management – The Advisor’s investment philosophy is based primarily on modern portfolio theory. The Advisor will develop a strategic asset allocation for the Client based on the Client’s unique situation. The Advisor will then construct an investment portfolio primarily utilizing exchange-traded funds (“ETFs”). The Advisor may also incorporate open-end mutual funds, individual equity securities and/or individual fixed income securities in a Client’s portfolio. For mutual funds, the Advisor primarily selects passive managers and will seek institutional share classes when available. Veery Capital, LLC typically employs a long-term investment approach for Clients, but may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Veery Capital, LLC will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Veery Capital, LLC will provide investment management and related advisory services. At no time will Veery Capital, LLC accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client Investment Advisory Agreement. Use of Independent Managers - Veery Capital, LLC may recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent Managers”). Independent Managers may be sourced directly or accessed through an investment management platform. The Client will be required to enter into a separate agreement with the Independent Manager[s]. Veery Capital, LLC serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. Veery Capital, LLC will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s. Veery Capital Page 5 will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties. Financial Planning Services Veery Capital, LLC will typically provide to its Clients a variety of financial planning services. Such services may be included in the overall advisory services or contracted separately, based on the Client’s needs and complexity of the services to be provided. Services may be provided in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Planning or consulting may encompass one or more

areas of need, including, but not limited to investment planning, retirement planning, distributions, personal savings, education savings, spending, insurance needs, estate planning, charitable strategies, and other areas of a Client’s financial situation. Veery Capital, LLC may deliver specific planning modules to the Client or a comprehensive plan, based on the needs of the Client. In certain circumstances, Veery Capital, LLC may also refer Clients to an accountant, attorney or other specialist, as appropriate for the Client’s unique situation. For certain financial planning engagements, the Advisor will generally provide a written report that contains observations and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Financial planning services may be included in an overall wealth management engagement or provided as a separate service, pursuant to the terms of the agreement with the Client. Retirement Plan Advisory Services Veery Capital, LLC provides advisory services on behalf of company retirement plans (each a “Plan”) and the company/sponsor (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education
• Investment Policy Statement (“IPS”) Design and Monitoring
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance These services are provided by Veery Capital, LLC serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Veery Capital’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Veery Capital offers a financial wellness program, WellCents, for the participants in our retirement plans who opt into this service for an additional fee. WellCents gives the participants a holistic review of their financial situation while eliminating any extra burden on human resources. This is a benefit provided through the employer in which an additional fee is charged. All investment changes are self-directed by the participant. Selection of Other Advisers Fees Veery Capital, LLC and their affiliated IARs, from time to time, will recommend certain Third Party Administrators and Record Keepers for ERISA plans. The Firm charges an advisory fee to the ERISA plan sponsor company that is separate and distinct from the fee the sponsor company may pay the Third Party Administrator or Record Keeper. In certain instances, the Third Party Administrator and/or Record Keeper will receive compensation for group benefit plans offered, and IARs affiliated with Veery Capital may receive a percentage of that compensation. This relationship Page 6 is fully disclosed to clients. Educational Seminars The Advisor offers educational seminars to clients and prospects. C. Client Account Management Prior to engaging Veery Capital, LLC to provide advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Veery Capital, LLC will work with each Client to develop a custom investment strategy designed in connection with the Client’s investment goals and objectives.
• Asset Allocation – Veery Capital, LLC will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – Veery Capital, LLC will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Veery Capital, LLC will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Veery Capital, LLC does not participate in any wrap fee programs. E. Assets Under Management As of December 2023, Veery Capital, LLC has $405,110,624.00 under non-discretionary and has $333,954,141.00 under discretionary and a total of $739,064,765.00 assets under management. Page 7