A. ICR Partners, LLC (the “Registrant”) is an LLC formed on April 1, 2019 in the State of Indiana. The Registrant became registered as an Investment Adviser Firm on January 24, 2020. Robert Mehringer is the Registrant’s Chief Compliance Officer, President and Chief Investment Officer. B. Registrant provides fee-only investment advisory and consulting services via proprietary research, investment-related consulting services, investment platforms and asset management programs to Clients (“Clients”). Registrant exclusively serves institutional Clients (banks, trust companies, broker/dealers, other investment advisers, institutional retirement plans, etc.). Registrant’s services are provided to institutional entities. To the extent that Registrant’s Clients utilize its services to provide investment advisory services for their Customers, the Client is responsible for initial and ongoing suitability determination, Customer communications, designation of custodian/broker-dealer, and corresponding best execution. Registrant does not offer financial planning or related consulting services directly to Customers or other individuals. INSTITUTIONAL INVESTMENT ADVISORY SERVICES 1. Investment Model Research Program The Registrant offers investment management access and advice not involving supervisory services on a non-discretionary basis, through the Investment Model Research Program (“IMRP”) to banks, trust companies and others who are trustees, investment management agents or who may otherwise have discretionary authority over certain Customer portfolios, broker-dealers or registered investment advisers; all such parties herein described as the “Client’s Fiduciary Agent”. Under the IMRP, the Registrant contracts for the investment advice of third-party investment managers called “Model Providers,” who provide purchase or sale recommendations based on their research. The Registrant’s role in the IMRP is to make available one or more third party investment managers to an Overlay Manager, and to supply the Overlay Manager with investment recommendations received from Model Providers. The Overlay Manager invests the assets in a Client’s IMRP account based upon the Client information received from the Customer or the Client’s Fiduciary Agent. For selected third party managers that are designated on the Registrant’s approved list, the Registrant approves the Model Providers for inclusion in the IMRP based upon a comprehensive review and analysis of their investment strategies, performance information and other inquiries as the Registrant may find necessary. The Registrant then forwards such information received from the Model Providers to the Overlay Manager on a regular basis, which allows the Overlay Manager to construct investment portfolios for Customers. In certain cases, the Client’s Fiduciary Agent may serve as the Overlay Manager, a Model Provider, or both. Initial and ongoing reviews of the Model Providers are conducted by the Registrant’s Research Committee and include the analysis of investment information. The Registrant requires performance information of Model Providers on the Registrant’s approved list to be provided in a format which is Global Investment Performance Standards (GIPS) compliant. Exceptions to this compliance requirement may apply if the Model Provider has demonstrated a strong investment management background. The review may include comparisons to investment advisers with similar investment styles. In some cases, an on- site or a virtual visitation is conducted with the Model Provider. Model Providers that successfully complete this process are placed on the Registrant’s approved list and are then available for use in the Customers’ investment portfolios by the Overlay Manager. Credentials and select data of Model Providers are reviewed each quarter to determine if expectations have been met on a relative basis to remain eligible for inclusion in the IMRP. If general expectations have not been met, a more comprehensive review may be conducted, after which replacement of the Model Provider may occur. In selecting the appropriate investments for a particular Customer’s IMRP account, the Client’s Fiduciary Agent determines which combination of investment recommendations provided by Model Providers through the Registrant are appropriate and suitable for a particular Customer account based upon the Customer’s investment objectives, financial situation, risk tolerance and other investment guidelines. Additionally, Client’s Fiduciary Agent may, on occasion, request assistance from Registrant in the selection of these model Model Providers. The Overlay Manager has discretion as to the specific timing and manner of execution of investment transactions based upon Customer information it has received from the Client’s Fiduciary Agent. The Registrant and Model Providers selected by the Registrant’s

Research Committee may jointly host seminars from time to time to promote the benefits of the IMRP to various financial institutions. Model Providers commonly share seminar and nominal entertainment expenses with the Registrant, however, a Model Provider’s willingness or unwillingness to participate in such seminars or to share in such expenses does not positively or negatively impact the evaluation or assessment of such Model Provider by the Research Committee. 2. Investment Advice through Consultations The Registrant offers additional investment consulting services through which investment advice may be provided. These services encompass internet platform design, program evaluation, asset allocation, and custom research. MISCELLANEOUS Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the Client’s Fiduciary Agent or from the Client’s Fiduciary Agent’s other professionals and is expressly authorized to rely thereon. Moreover, each Client’s Fiduciary Agent is advised that it remains his/her/its/their responsibility to promptly notify the Registrant if there is ever any change in the Customers’ financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Other Services. The Registrant may provide administrative, investment consulting and due diligence services for Client’s Fiduciary Agents who provide services to Customers on a wrap fee basis. When considering wrap fee arrangements, Client’s Fiduciary Agent’s Customers should note that they might pay a higher fee than would be charged for investment advice or management alone. However, depending upon the volume of transactions in the Customer’s account, an all-inclusive fee arrangement may result in a comparable or lesser total charge. Private Investment Funds. Registrant may provide investment advice regarding unaffiliated private investment funds. The Registrant’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a Client determines to allocate investment assets among a private investment fund, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Registrant calculating its investment advisory fee. Registrant’s Clients are under absolutely no obligation to consider or allocate investment assets among private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each Client for review and consideration. Unlike liquid investments, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client investor shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2A of Form ADV shall be provided to each Client’s Fiduciary Agent and/or Customer prior to, or contemporaneously with, the execution of the Investment Advisory Agreement, as required by law. Fee Differentials. As indicated below, the Registrant shall price its services based upon various objective and subjective factors. As a result, Registrant’s Clients could pay diverse fees based upon the market value of their assets, the complexity of the engagement, and the level and scope of the overall investment advisory and/or consulting services to be rendered. As a result of these factors, the services to be provided by the Registrant to any particular Client could be available from other advisers at lower fees. All Clients and prospective Clients should be guided accordingly. C. The Registrant shall provide investment advisory services specific to the needs of each Client’s Fiduciary Agent. Prior to providing investment advisory services, an investment adviser representative will ascertain each Client’s Fiduciary Agent’s objective(s). Thereafter, the Registrant shall allocate and/or recommend that the Client’s Fiduciary Agent allocate investment assets consistent with the designated investment objective(s). The Client’s Fiduciary Agent may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. The Registrant does not participate in a wrap fee program. E. As of December 31, 2023, the Registrant had $224,868,995 of Regulatory Assets under Management on a discretionary basis.