A. Description of the Advisory Firm Cobblestone Asset Management LLC (hereinafter “Cobblestone Asset Management”) is a Limited Liability Company organized in the State of Virginia. The firm was formed in March 2019, and the principal owner is Cobblestone Asset Management. B. Types of Advisory Services Portfolio Management Services Cobblestone Asset Management offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Cobblestone Asset Management creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Cobblestone Asset Management evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Cobblestone Asset Management seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Cobblestone Asset Management’s economic, investment or other financial interests. To meet its fiduciary obligations, Cobblestone Asset Management attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Cobblestone Asset Management’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Cobblestone Asset Management’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Platform Services Cobblestone Asset Management may provide their platform to advisors unaffiliated with Cobblestone Asset Management. These third-party advisors would utilize Cobblestone Asset Management's platform to provide portfolio management services to their clients. This relationship will be memorialized in each contract between Cobblestone Asset Management and the third-party advisor. Cobblestone Asset Management will have no contact with the third-party advisors' clients. The third-party advisor will be responsible for client due diligence, suitability, and providing Cobblestone Asset Management with discretionary authority, if applicable. Selection of Other Advisors Cobblestone Asset Management may direct clients to third-party investment advisors. Before selecting other advisors for clients, Cobblestone Asset Management will verify that all recommended advisors are properly licensed, notice filed, or exempt in the states where Cobblestone Asset Management is recommending the advisor to clients. Services Limited to Specific Types of Investments Cobblestone Asset Management generally limits its investment advice to equities, fixed income securities, real estate funds (including REITs), ETFs (including ETFs in the gold and precious metal sectors), mutual funds treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements, and insurance products including annuities although Cobblestone Asset Management primarily recommends ETFs. Cobblestone Asset Management may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the

meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions Cobblestone Asset Management will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by Cobblestone Asset Management on behalf of the client. Cobblestone Asset Management may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Cobblestone Asset Management from properly servicing the client account, or if the restrictions would require Cobblestone Asset Management to deviate from its standard suite of services, Cobblestone Asset Management reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. Cobblestone Asset Management acts as portfolio manager for and sponsor of a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. However, this brochure describes Cobblestone Asset Management’s non-wrap fee advisory services; clients utilizing Cobblestone Asset Management’s wrap fee portfolio management should see Cobblestone Asset Management’s separate Wrap Fee Program Brochure. Cobblestone Asset Management manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accountings holding primarily, and for any substantial period of time, cash or cash equivalents investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. E. Assets Under Management Cobblestone Asset Management has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $134,064,081 $0 September 2023