ADVISORY FIRM DESCRIPTION Vaquero Private Wealth, Ltd. (“VPW” or the “Firm”) has been in business since August 2017. John B. Gordon and Laura C. Blair are the owners of the firm. TYPES OF ADVISORY SERVICES VPW is an independent financial advisor providing clients with a detailed personalized approach on a discretionary basis. VPW consults with clients regarding their personal financial goals and objectives and designs and maintains their portfolios accordingly. INVESTMENT MANAGEMENT SERVICES VPW invests client assets on a discretionary and/or non-discretionary basis in consideration of their risk tolerance and financial condition to help them achieve their investment objectives. These investments are monitored in light of changes to current market conditions, client objectives and/or risk tolerance. See Item 8 for more information on VPW’s investment objectives. Our investment management process is to:
• Determine your risk tolerance and financial goals
• Develop an appropriate asset allocation strategy
• Invest your portfolio according to your risk tolerance and objectives
• Make tactical changes reflecting current economic and market conditions
• Conduct periodic meetings with you to review your performance, risk tolerance and objectives Please see the “Methods of Analysis, Investment Strategies and Risk of Loss” Item 8 below for more details. We do not participate in any wrap fee programs in which investment management and transaction fees are “wrapped” into one fee. External Managers: VPW may recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by external money managers (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. In addition to this Brochure, clients may also receive the written disclosure documents of the respective External Managers engaged to manage their assets. VPW also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are typically exclusive of, and in addition to, advisory fees charged by VPW. To the extent possible, VPW seeks to assess the External Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Private Investments: For specific qualified clients, VPW recommends investment in private investment vehicles whose interests are not publicly offered under the Securities Act of 1933 (“Private Funds”). Such Private Funds may be structured as fund of funds or as access vehicles to underlying funds or portfolios managed by third-party investment advisors. VPW will, from time to time and as appropriate, solicit clients to invest in such vehicles, and decide which clients to approach for some or all of these investments, in its own discretion. VPW advisory fees charged to clients for investing in a Private Fund are in addition to the fees charged by the Private Funds to investors. It should also be noted that certain employees of VPW may directly participate through the Private Fund itself for the purposes of investing. ERISA Services and Retirement Investments: We are deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (“IRAs”) pursuant to the Employee Retirement Income and Securities Act (“ERISA”), and regulations under the Internal Revenue Code of 1986 (“the Code”), respectively. As such, we are subject to specific duties and obligations under ERISA and the Code that include among other things, restrictions concerning certain forms of compensation. We may assist you with retirement plan accounts and this assistance may present a conflict of interest. When you leave an employer there are typically four options regarding an existing retirement plan account and you may use a combination of these options; 1) if permitted, leave the funds in your former employer’s plan, 2) if roll overs are permitted and you have new employer with a plan available, roll over the funds to your new employer’s plan, 3) roll over to an Individual Retirement Account (“IRA”), or 4) withdraw or cash out your funds from the plan which may have adverse tax consequences depending on your age. When we recommend that you roll over your retirement plan assets into an account to be managed by us, such a recommendation creates a conflict (benefit to us) when we earn an advisory fee on your rolled over funds. You are under no obligation to roll over retirement plan assets to an account managed by us. In addition to providing advisory services with respect to participation in employer- sponsored retirement plans and individual retirement accounts, VPW can provide advisory services to the sponsors of defined contribution, defined benefit and non- qualified deferred compensation plans who have ultimate authority to direct the investing and reinvesting of plan assets as they deem appropriate, considering each plan’s stated objective, liquidity needs, and stated policies and guidelines. VPW is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, prohibited

transaction rules which are intended to prohibit fiduciaries from engaging in specified conflicts of interest. Donor Advised Services: Certain VPW clients have donor advised funds through various third-party charitable programs including the Fidelity Charitable Gift Fund Program, the Schwab Charitable Fund and the American Endowment Foundation (each, a “Charitable Platform”), which funds will be managed in accordance with the specific investment policies and guidelines of the applicable Charitable Platform. Clients will establish a donor advised account, transfer funds earmarked for charitable donation and recognize a tax deduction in the year that funds are transferred into an account opened on a Charitable Platform. The funds remain in such account until the Client designates a charity, an amount, and a date to donate to such charity. Under independent advisor programs established within each Charitable Platform, donors nominate an independent investment adviser, including VPW, to manage accounts established on the Charitable Platforms. If nominated, VPW will manage the donor's account pursuant to investment guidelines established by each Charitable Platform. Reporting on Non-Advisory Assets: VPW will provide consolidated reporting on Client non-advisory assets when requested. Non-advisory assets are assets independently owned by Clients but not included as assets under management by VPW. These non-advisory assets will not be subject to VPW’s investment review and no investment advice will be provided with respect to non-advisory assets. VPW will report the value of each non-advisory asset to the Client, based solely on the valuations received by VPW from the third-party managers of the non-advisory assets or other third parties, but VPW will not have any obligation to independently examine, confirm or review non-advisory asset valuations. FINANCIAL PLANNING We believe that before quality advice can be offered, it is essential to understand your goals. By listening closely to your concerns and objectives, we can create a financial planning strategy that accelerates you toward your goals. Our wealth advisors develop a clear financial planning roadmap that fully leverages your available resources to reach your objectives. The scope of our planning services includes the following to the degree any client needs:
• Net Worth/Cash Flow Analysis We evaluate your current assets and liabilities, as well as all income and expenses. We also consider potential inheritances, salary changes, or major one- time expenses.
• Retirement Planning We utilize a sophisticated set of tools to measure and analyze various assumptions including retirement dates, savings rates, longevity expectations, and market conditions.
• Tax Planning We work in concert with your tax professional to identify any areas of opportunity that might impact your current and future tax situation.
• Insurance Planning We work with your insurance agents to review and coordinate coverage for homeowners, auto, liability, disability, life, and long-term care insurance.
• Estate Planning and Asset Protection We work with your attorney to review your existing estate planning documents and/or create a plan that seeks to protect and distribute your assets to your heirs according to your wishes with the goal of minimizing taxes and expenses.
• Education Planning We advise you on how to leverage tax-advantaged education saving options and other vehicles to provide for educational expenses.
• Business Owners We partner with other professionals to assist in evaluating merger and acquisitions transactions, employee benefits packages, succession planning strategies, and lending options..
• Corporate Executives We assist clients at the corporate executive level on how to optimize the exercise of stock options and minimize the tax implications. We also assist with the review of other corporate benefits.
• Charitable Planning We compare suitable solutions and then help you direct your giving through tools that provide the maximum impact for your selected charitable causes and maximize your tax benefit. TAILORED ADVISORY AND CONSULTING SERVICES We tailor each financial plan, our investment management recommendations to you and provide other client-specific consulting, as needed. You may restrict us from buying or selling particular investments in your portfolio. These restrictions may be changed at any time by notifying us. THIRD PARTY SERVICE PROVIDERS Vaquero works with third-party service providers to help support the operational needs of managing and servicing discretionary Advisory Accounts of held away assets such as defined contribution plan participant accounts and 529 plans. VPW also uses a third-party to support the private investment operations including capital calls which has a data feed to VPW’s data aggregator and trading platform. This third party is related to VPW’s data aggregator and provides valuation and billing support for the firm’s clients’ private investments. For assets that are valued by this third party, that overrides the custodial valuation feed if the two differ. CLIENT ASSETS UNDER MANAGEMENT As of December 31, 2023, the Firm had $657,749,636 in discretionary assets under management and $22,575,867 in non-discretionary assets under management for a total of $680,325,503 in assets under management.