A. Firm Information Pallas Capital Advisors LLC (“Pallas” 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 Delaware in March 2019 and became a registered investment advisor in November 2020. Pallas is a wholly-owned subsidiary of MBE, LLC. In 2021, the owners of Pallas contributed 100% of their ownership interests to MBE, LLC. MBE, LLC is owned by Richard S. Mullen (Managing Member), Charles C. Evangelakos (Managing Member), and Gregory E. Boyle (Managing Member). The Advisors is managed by Richard S. Mullen (Managing Director & Co-Founder), Charles C. Evangelakos (Managing Director & Co-Founder), and Gregory E. Boyle (Managing Director & Co-Founder). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Pallas. For information regarding this Disclosure Brochure, please contact James C. Landry (Chief Operating Officer & Director of Planning / Chief Compliance Officer) at (781) 971-5052. B. Advisory Services Offered Pallas offers wealth management services which include investment management, financial planning and/or other advisory services to individuals, high net worth individuals, trusts, estates and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to 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 potential conflicts of interest. Pallas'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 Pallas provides customized wealth management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management, financial planning, and related advisory services as described below. Investment Management – Pallas 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. Pallas will then construct an investment portfolio, consisting exchange-traded funds (“ETFs”), open-end mutual funds, individual stocks, individual bonds, and closed-end mutual funds. The Advisor may also utilize covered options, alternative investments, limited partnerships, and/or other types in investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations. Pallas’ investment approach are 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. Pallas 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. Pallas evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Pallas may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Pallas may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Pallas 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. Pallas will provide investment management services and related services. Pallas accepts custody of a Clients funds or securities, through the deduction of management fees from the Client’s account[s] at the Custodian, and in certain Page 5 situations where a Supervised Person of Pallas may act as trustee or power of attorney for client accounts. For more information see 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 deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), 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). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. 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 – Pallas may 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. 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 will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosure Financial Planning Services – Pallas will typically provide a variety of financial planning and consulting services to Clients as part of a wealth management engagement. Certain Clients may be offered financial planning and consulting services as a separate engagement, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. 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, insurance needs, and/or 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. Pallas 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 may 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. However, 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. Family Office Services The Advisor also provides Family Office Services. Family Office Service Clients are generally ultra-high net worth families. This high-touch service offering begins with the Advisor assisting Clients in establishing a team of advisors to Page 6 oversee many facets of a Client's’ financial situation. The Advisor’s specific services generally include, strategic and tactical planning in addition to investment management services. Strategic planning may include, but is not limited to:
• Family Values Identification and Alignment
• Family Communication Planning & Implementation
• Family Education and Leadership Development
• Family Governance & Role Clarification
• Family and Business History
• Retreats and Education
• Philanthropy Tactical planning may include, but is not limited to:
• Family Enterprise Administration, Consulting and Succession Planning
• Net Worth Management
• Estate and Tax Planning
• Risk Management and Insurance
• Strategic and Thematic Investing
• Impact Investing and Philanthropy Retirement Plan Advisory Services Pallas 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: ● Vendor Analysis ● Plan Participant Enrollment and Education Tracking ● Investment Policy Statement (“IPS”) Design and Monitoring ● Non-discretionary Investment Oversight Services (ERISA 3(21)) ● Discretionary Investment Management Services (ERISA 3(38)) ● Performance Reporting ● Ongoing Investment Recommendation and Assistance These services are provided by Pallas 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 Pallas’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Investment Consulting Services The Advisor provides investment consulting services to certain third party registered investment advisors (herein “Third Party”). In such instances, the Advisor shall provide recommendations to Third Parties regarding the investment and reinvestment of the Third Party’s client accounts in accordance with the investment objectives, guidelines, restrictions, and investment strategy set forth in the information provided to the Advisor by the Third Party. The Third Party will determine, in its sole discretion, the securities to be purchased or sold or exchanged and what portion, if any, of the assets shall be held un-invested for that portion of the Third Party’s client account’s. The Third Party is not obligated to implement the Advisor’s recommendations. The Advisor does not have trading authorization for any of the Third Party’s client accounts. C. Client Account Management Prior to engaging Pallas 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: Page 7
• Establishing an Investment Strategy – Pallas, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Pallas 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 – Pallas will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Pallas will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs In certain instances, Pallas includes securities transaction fees, custodial costs, and other fees and expenses (herein “Covered Costs”) together with its investment advisory fees as a single, bundled fee. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients and does not provide different services for Clients in the Wrap Fee Program. The Advisor does not charge a higher fee for inclusion in its Wrap Fee Program. The Advisor sponsors the Pallas Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client will pay more or less in total fees than if the Client had paid its own transaction fees. To mitigate conflicts of interest, Pallas has negotiated a fixed rate with Fidelity Investments, Inc. for Covered Costs, which are based on assets under management in the Client’s account[s]. Charles Schwab & Co., Inc. may charge individual securities transactions costs to the Advisor, depending on the type on investments traded. Please see Item 5.C. as well as Item 12 and Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of October 30th, 2023, Pallas manages $2,283,471,370 in discretionary assets and $12,105,155 in non-discretionary assets. Total assets under management are $2,295,576,525. Clients may request more current information at any time by contacting the Advisor.