Ategenos Capital, LLC, (“Ategenos” or “we”, “us” and “our”) is a registered investment adviser located in Berwyn, Pennsylvania. Ategenos was founded in 2022 and is organized as a Delaware Limited Liability Company (“LLC”). Ategenos is majority owned and controlled by 366, LLC. 366, LLC, a Delaware Limited Liability Company, is an entity created and intended for employees of Ategenos to have ownership in Ategenos. A minority ownership interest is held by Envestnet Holdings, LLC, a wholly-owned subsidiary of Envestnet, Inc. (“Envestnet”), a publicly held company founded in 1999 and whose stock is traded on the New York Stock Exchange under the ticker symbol ENV. Types of Advisory Business Ategenos strictly offers registered investment advisory services and is not affiliated with any broker-dealer and does not provide investment banking or broker-dealer services. Ategenos specializes in providing multi-asset class investment solutions through program sponsor (“Sponsor”) platforms intended for Sponsor financial representatives and their clients (“Clients”). Model Portfolios Sponsors receive Ategenos investment model portfolios and, based on that model, the Sponsor, or its designated service provider (“Overlay Manager”) exercises investment discretion and executes each Client’s portfolio transactions predicated on the Sponsor’s or Overlay Manager’s own investment judgment in line with Client’s investment objectives. Sponsor programs are referred to as Model-Based Programs. Ategenos typically provides its model portfolios which may be comprised of various investment funds (mutual funds and exchange traded products), Separately Managed Accounts (SMA), and/or SMA model portfolios to the Sponsor or Overlay Manager, who subsequently, provides investment advice to Sponsor Clients, based on Client individual needs. Ategenos model portfolios generally are risk-based portfolios but also may include but are not limited to goals-based portfolios and asset class specific portfolios. When changes are made to a model portfolio by Ategenos, the Sponsor or Overlay Manager is responsible for implementing any modifications in Client accounts that are invested in the specific strategy. The Sponsor/Overlay Manager may or may not elect to execute all the purchase and/or sale transactions suggested by submissions of revisions in the model portfolio. Ategenos does not enter trades, receive trade reports, or have access to any Client reporting related to these accounts. It is the responsibility of the Sponsor or Overlay Manager to determine whether our model is suitable for Sponsor Clients. Portfolio performance dispersion is expected between the account performance in Model-Based Programs and Ategenos portfolios. Private Wealth Through a Sponsor program, Ategenos may provide discretionary investment management services generally to Clients with household assets of $1 million and above or institutional clients. Ategenos works with Sponsor financial representatives and Clients to determine Client portfolio needs, investment objectives, financial position, and limitations to design an asset allocation and investment plan to meet Client goals. A typical Client relationship will have a Sponsor financial representative to assist the Client through the implementation process and work with Ategenos with on-going portfolio management of the 5 | P a g e Client’s assets. Ategenos allows for tailoring of Client portfolios by working with a Client’s already existing portfolio to efficiently construct what Ategenos believes to be an appropriate portfolio (i.e., utilizing existing securities where appropriate), managing across multiple types of account registrations, allowing Clients to place restrictions on securities, types of securities and investment strategies, and managing a Client’s portfolio in seeking to meet specific distribution needs and tax goals. Ategenos cannot accommodate some restrictions for Client investments in underlying pooled investment vehicles. In working with Clients to implement a tailored investment solution, Ategenos recommends the use of various investment funds (mutual funds and exchange traded products), SMAs and SMA model portfolios, and potentially alternative investments to provide exposure to capture potential returns from specified asset classes. When changes are made to a Client portfolio by Ategenos, the Sponsor or Overlay Manager is responsible for implementing any modifications in Client accounts that are invested in the specific strategy. The Sponsor/Overlay Manager may or may not elect to execute all the purchase and/or sale transactions suggested by submissions of revisions in the portfolio. Ategenos will have Client contact and will receive trade reports and access to Client reporting related to these accounts. It is the responsibility of the Sponsor or Overlay

Manager to determine whether our portfolio is suitable for Clients. Ategenos may recommend Tax Management Services for Client’s taxable accounts. Tax Management Services will be provided by the Overlay Manager, and not Ategenos. Tax Management Services will only be recommended by Ategenos if Sponsor has approved this service. The tax strategy developed is provided solely in connection with Client account(s) and Ategenos does not provide general tax planning services and you should consult your tax advisor. If you do elect the Tax Management Services option, the following should be considered:
• Tax Management Services are limited in scope and are not designed to eliminate taxes in the account. Neither Ategenos nor Overlay Manager make any guarantee that tax liability in the account will be reduced or that any indicated limits will be met.
• If Client selects Tax Management Services for the account, information provided by Client may result in Overlay Manager making substantial deviations from the investment allocation on a more than temporary basis. The use of limits to restrict the amount of capital gains realized or Client’s total tax bill may severely restrict trading in the account and could result in substantial deviations from the investment allocation. Limits should only be imposed on the account after Client has consulted with their tax advisor. Capital gains specified will be used annually until Client specifies otherwise. Certain cash management services (e.g., Dollar Cost Averaging) may be recommended by Ategenos for Clients that are seeking to invest or transition assets over certain time periods. Cash management services will be administered by the Overlay Manager and not Ategenos. Cash management services will only be offered if Sponsor has approved these services. Additional services that Ategenos may include in discussions include, but are not limited to, securities backed lines of credit, trust services, and financial planning. These services will only be recommended by Ategenos if Sponsor has approved the offering to be eligible to their Clients. For these services as well as 6 | P a g e Tax Management Services and cash management services, please refer to the Sponsor’s Form ADV Part 2A for additional information. Outsourced Chief Investment Officer Services Ategenos provides investment services to asset managers and other registered investment advisers that may include:
• Advice on governance and fiduciary framework and structure;
• Assisting clients with developing and documenting investment objectives, risk tolerance, and cash flow needs relative to market opportunities;
• Establishing and advising on asset allocation and portfolio composition;
• Providing our macro-economic forecast, based on outlook for various major and sub-asset classes;
• Providing research and guidance on third party money managers;
• Recommending the client select certain investment strategies, retain, or terminate certain money managers, or reallocate assets among various managers or strategies;
• Performance evaluation;
• Creation of materials for staff analysis, as well as committee consideration and education. The client is responsible for weighing our advice in these areas and making the final strategic decisions related to its plans, including governance structure, asset allocation, risk and liquidity needs, and investment policy statement. When serving as a consultant, we do not have investment discretion over client funds and do not make specific investments of client assets or make recommendations with respect to specific securities. We may also provide non-investment management due diligence reviews which cover a third-party investment adviser’s business structure, operations, and technology. In certain contractual arrangements, Ategenos may serve as a sub-adviser to provide discretionary investment services for the asset manager or registered investment adviser. Global Managed Account Program (“gMAP”) Ategenos offers gMAP to support financial institutions to have the ability to provide investment advisory services generally to offshore clients through a fee-based program. Ategenos provides financial institutions investment related support by providing asset allocation advice, investment portfolio recommendations, curated investment product inventories, wealth management platform technology recommendations, investment program guidance and practice management support. Upon request, Ategenos may provide guidance to the financial institution to build, design, and implement investment models that are white-labeled for the financial institutions exclusive use. Assets Under Management As of July 31, 2023, Ategenos has $106,664,472 in discretionary assets under management.