A. Firm Information Thayer Partners LLC (“Thayer” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of the Commonwealth of Massachusetts. Thayer was founded in December 2011, and is owned and operated by John C. Wilmerding (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Thayer. B. Advisory Services Offered Thayer offers customized wealth management services and related advisory services to individuals, high net worth individuals, trusts, estates, other investment advisors and retirement plans (each referred to as a “Client”). Thayer’s Chief Investment Officer (“CIO”) oversees the strategic reviews of the Firm’s overall investment management practices, including, development of strategies, portfolio disciplines and other pertinent matters to our business. Thayer’s capabilities include furnishing advisory services to both U.S. based investors and offshore investors. The Advisor serves as a fiduciary to its Clients, as defined under the 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 conflicts of interest. Thayer’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Thayer provides customized wealth management services for its Clients. The Advisor’s wealth management services include regular and continuous Client interactions integrated with ongoing investment management and financial planning services. Investment Management Services – Thayer works closely with each Client to identify their investment goals and objectives, as well as risk tolerance and financial situation in order to create a portfolio strategy. Thayer will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Thayer’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Thayer 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. Thayer evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Thayer may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Thayer may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movements. Thayer may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Thayer accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement Page 6 accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers – Thayer will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Financial Planning Services – Thayer will typically provide a variety of financial planning and consulting services to Clients as a component of wealth management services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. and financial circumstance. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the

Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Thayer may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, 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 (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of 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. At Thayer’s discretion, clients and/or prospective investors may be charged a fixed annual consulting fee to provide tax planning, financial planning and estate planning reviews. Retirement Plan Advisory Services Thayer provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (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 its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Page 7 ● Vendor Analysis ● Plan Participant Enrollment and Education Tracking ● Investment Policy Statement (“IPS”) Design and Monitoring ● Investment Oversight Services (ERISA 3(21)) ● Investment Management Services (ERISA 3(38)) ● Performance Reporting ● Ongoing Investment Recommendation and Assistance ● ERISA 404(c) Assistance ● Benchmarking Services These services are provided by Thayer 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 Thayer’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Business Advisory Services Thayer provides business advisory services for its clients, which includes regular interactions during limited engagements as well as continuous engagements. Client interactions may be integrated with financial planning services. Thayer assists their Client’s in the management of their business(es) in an effort to maximize business profits and owner’s benefits. Thayer works closely with each Client to evaluate their business financials and operations to develop new approaches, where and when it is deemed appropriate, to cash management, expense management, product and service delivery, pricing, staffing, and customer optimization. For certain business advisory engagements, the Advisor will provide a written summary of Client’s situation, observations, and recommendations. For other engagements, the Advisor may not provide a written summary. Thayer is a member of Profit First Professionals, a membership organization made up of accounting, bookkeeping and coaching professionals who provide consulting services to small business owners on how to implement strategies aimed to improve cash flow. Thayer is also a Certified Profit First Professional, having received certification after completing 25 hours of coursework, instruction and training on the specific strategies and methodology that Profit First was founded on. This work was completed via a combination of individual and group sessions as well as individual course work on Profit First’s platform. Utilizing any strategies intended to improve business cash flow that are born out of the Profit First methodology is no guarantee of results and should not be construed as such. [Business advisory service engagements pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for wealth management services or to increase the level of investable assets with the Advisor, as it would increase the amount of 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. Any recommendation that the Advisor provides as it relates to business advisory services are non-investment or wealth management related and strictly pertain to the sustainability and profitability of the business(es). 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. C. Client Account Management Prior to engaging Thayer to provide investment 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 – Thayer, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Thayer will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk of each Client. Page 8
• Portfolio Construction – Thayer will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Thayer will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Thayer does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Thayer. E. Assets Under Management As of December 31, 2023, Thayer manages approximately $294,842,324 in regulatory assets under management (“RAUM”), of which $108,584,251 is managed on a discretionary basis and an additional $186,258,073 is managed on a non-discretionary basis. Thayer’s assets under advisements, which is an amount separate and additional from its RAUM, was approximately $142,985,294 as of December 31, 2023. Clients may request more current information at any time by contacting the Advisor directly at (617) 275-5430.