A. Description of the Advisory Firm Stonegate Investment Group, LLC (“Stonegate” or the “Advisor”) is a limited liability company (“LLC”) organized in the State of Delaware. Stonegate is an investment advisory firm registered with the U.S. Securities and Exchange Commission (“SEC”). Stonegate Investment Group, LLC is wholly-owned by Stonegate Investment Group Holdings, LLC. As of July 9, 2021, the majority of Stonegate Investment Group Holdings, LLC is owned, directly or indirectly, by Tony R. Smith (Chief Executive Officer, Chief Investment Officer), Christopher J. Compton (Managing Director, Partner), Matthew C. Brown, CFP® (Managing Director, Partner), and James W. Allen (Chief Wealth Strategist, Partner). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Stonegate. For informational regarding this Disclosure Brochure, please contact Harry Cowley (Chief Compliance Officer) at (205) 963-0840. B. Types of Advisory Services Stonegate provides investment advisory services to individuals, including high net worth individuals, and entities, including family offices, trusts, estates, private foundations, charities, small businesses, and pension and retirement/profit-sharing plans (each a “Client”), on a fee-only basis. Stonegate may also assist Clients in determining their financial objectives, identifying financial issues, analyzing cash flow, tracking and reporting on financial assets, and counseling on issues related to education funding, retirement planning, risk management, gifting, and tax and estate planning. Stonegate also provides investment advisory services to corporate, governmental and not-for-profit retirement plans pursuant to The Employee Retirement Income Security Act of 1974 (“ERISA”). 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. Stonegate’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. Investment Management Services Stonegate provides discretionary and non-discretionary management of Client investment portfolios on a customized and individualized basis in accordance with each Client’s financial goals, liquidity constraints, time horizon, lifestyle, risk tolerance and tax sensitivity. The Advisor primarily invests Client assets in equity securities of individual companies, bonds, mutual funds, exchange-traded funds (“ETFs”), and limited partnerships and pooled investment vehicles focusing on alternative asset classes. Stonegate also uses options, typically covered call options, protective put options, and long put and call options in Client portfolios. Stonegate primarily allocates Client assets to the Stonegate Wrap Program (the “Wrap Fee Program”), an arrangement where the Client pays a single fee (the “Program Fee”) based on a percentage of the Client’s assets under management, for the Advisor’s investment advice, custody and commissions and transaction charges for securities transactions executed at a designated custodian. Stonegate is the Sponsor and Manager of the Wrap Fee Program. Clients are advised to promptly notify the Advisor if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Stonegate determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Advisor’s management efforts. Stonegate may recommend to Clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“Independent Managers”). The Client may be required to enter into a separate agreement with the Independent Manager(s), which will set forth the terms and conditions of the Client’s engagement of the Independent Manager, or will receive a Statement of Investment Selection in a single contract relationship. Stonegate generally renders services to the Client relative to the discretionary selection of Independent Managers. Stonegate also assists in establishing the Client’s investment objectives for the assets managed by Independent Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated Independent Managers are in addition to the annual advisory fee charged by Stonegate, as described below in Item 5. The amount of assets invested with Independent Managers is included in the Advisor’s “assets under management” for purposes of Stonegate Management calculating its annual advisory fee per Item 5 below. Stonegate evaluates a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, Stonegate seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its Clients’ individual portfolio allocations and risk exposure. Stonegate may also take into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. ERISA Services Stonegate provides investment management services to retirement plans (each a “Plan”) under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) on either a discretionary or nondiscretionary basis, depending on the Client and the Advisor’s arrangements with the Client. Stonegate acknowledges its status

as an ERISA fiduciary under either ERISA sections 3(21) or 3(38), as applicable, when providing investment management services. Stonegate’s fiduciary services to ERISA Plans include preparing an investment policy statement, screening and selecting investment options for the Plan, selecting a qualified default investment alternative, providing quarterly investment reports, attending the investment committee meetings, and, if the services are discretionary, creating and managing portfolios based on a range of varying target asset allocations. Stonegate’s non-fiduciary services to ERISA Plans can include providing education regarding general investment principles and the investments options in the Plan to Plan Participants. Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client roll over its Retirement Plan account into an account managed by the Advisor. 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”). Such a recommendation creates a conflict of interest as the Advisor will earn a new (or increase its current) advisory fee as a result of the rollover. No Client is under any obligation to roll over Retirement Plan assets to an account managed by the Advisor. Financial Planning and Consulting Services Stonegate may provide a variety of financial planning and consulting services to Clients. Such engagements are typically part of the investment advisory engagement, but may be pursuant to a separate financial planning engagement if agreed upon in advance by the Client and Stonegate. Generally, such financial planning services will involve preparing a financial plan or rendering a 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 cash flow analysis, investment planning, retirement planning, estate planning, personal savings, educational savings, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to a Client will typically 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. Stonegate may recommend its own services and/or the services of other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Stonegate recommends its own services, as such a recommendation may increase the advisory fees paid to the Advisor. The Client is under no obligation to act upon any of the recommendations made by Stonegate under a financial planning or consulting engagement to engage the services of any such recommended professional, including Stonegate itself. Private Fund Advisor Services Stonegate offers and provides investment management services to various pooled investment vehicles, (each a “Fund” and collectively the “Funds”). The Funds may only be offered to financially experienced and sophisticated investors able to bear the economic risk of an investment in the Fund and who qualify as “accredited investors” under Rule 501(a) of Regulation D of the Securities Act of 1933, as amended (the “Securities Act”) and “qualified clients” under Section 205-3 of the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”). The services provided are detailed in the respective offering documents for the Funds, which include as applicable, the operating agreement, private placement memorandum (“PPM”) and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (collectively the “Offering Documents”). Stonegate manages each Fund based on the investment objectives, policies and guidelines as set forth in the respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein (each an “Investor”). Each prospective investor interested in investing in a Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with such an investment. For more detailed information on investment objectives, policies, and guidelines, please refer to the respective Fund’s Offering Documents. C. Client-Tailored Advisory Services The Advisor’s investment advice is customized and tailored to the unique goals, objectives and needs of each Client. The Advisor seeks to understand the Client’s goals, objectives, time horizon, tax position and attitude toward risk and reward. The stated goals and objectives for each Client are reflected in the Client’s overall recommended financial and investment program and advice that is provided on an ongoing basis. D. Assets Under Management As of December 31, 2023, Stonegate manages $ 3,969,994,306 in discretionary assets and $671,029,681 in non-discretionary assets. Total assets under management are $4,641,023,987. In addition, the Advisor has assets under advisement of $246,000,000. Clients may request more current information at any time by contacting the Advisor. E. Wrap Fee Program As noted above, Stonegate is the Sponsor and Manager of the Stonegate Wrap Fee Program. When deemed to be in the Client’s best interest, the Advisor includes securities transaction fees together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. Depending on the level of trading required for a Client’s account[s] in a particular year, a Client may pay a higher or lower aggregate fee than if investment management and brokerage services were purchased separately. Please also see Appendix 1 (“Wrap Fee Program Brochure”), which is included with this Disclosure Brochure.