Introduction Prio Wealth is a wealth management firm that provides investment management and financial planning advice to high-net-worth individuals, families, and non-profit institutions. The Firm was founded in 1988 and is privately owned by the General Partner, Prio Wealth, Inc. and the Limited Partners. Prio Wealth is a fee-only, independent registered investment adviser located in Boston, Massachusetts. Prio Wealth’s vision is to help people live their one best financial life. It is Prio Wealth’s mission to guide clients in prioritizing not only what they are invested in but also what they’re investing for so that they can gain clarity, confidence, and control in their financial lives. Investment professionals manage client’s portfolios in a manner that is consistent with such client’s investment and financial planning objectives. Investment Management Prio Wealth provides an investment strategy tailored to the client’s long-term objectives to meet their overall personal financial goals and priorities. Each client is designated an experienced wealth adviser (“Adviser”). Prio Wealth uses both active and passive management strategies to manage portfolios, which typically include the use of cash, stocks, bonds and exchange traded funds (“ETFs”). ETFs are mostly used in smaller accounts and for diversification within portfolios that hold individual stocks. Prio Wealth has an environmental, social, and governance (“ESG”) overlay in evaluating individual stocks (see Item 8: Method of Analysis, Investment Strategies and Risk of Loss). Investment objectives can adjust over time as client circumstances change. Prio Wealth has full discretion for each account that it provides investment management services for, with the exception of a limited number of accounts where the Firm serves in the capacity of a financial consultant (see Item 16: Investment Discretion). Prio Wealth also provides trust services in the capacity

as corporate trustee for qualified trusts. Seaward Fiduciary Services, LLC (“SFS”) is a wholly owned subsidiary of Prio Wealth, Inc. The purpose of SFS is to provide corporate trusteeship and fiduciary services for individuals, businesses, non-profit organizations, and estates (see Item 10: Other Financial Industry Activities and Affiliates). Prio Wealth offers a wide range of wealth management services to aid clients in making financial decisions that are appropriate to meet their priorities. Services such as trust and tax administration as well as financial planning are also offered to clients depending on the client’s agreement with the Firm as part of their overall advisory fee. These services can be collectively referred to as financial life management. Financial Planning Prio Wealth has subscriptions with third-party technology vendors to support its financial planning advice. Prio Wealth offers financial planning services depending on client-specific needs. In those situations, Prio Wealth will use unique client engagement tools and often uses third-party financial planning software to meet the clients’ financial planning needs. Prio Wealth assesses the clients’ underlying values around money and utilizes a variety of third- party financial planning tools and technology platforms to obtain relevant information about the clients’ situation including, but not limited to, income sources, expenses, goals, assets, liabilities, tax situation, risk tolerance, liquidity needs, insurance policies and estate documents. Clients should not construe investment advice or other services provided by Prio Wealth to involve the rendering of any legal, tax or accounting advice. Prio Wealth strongly urges clients to consult with independent legal, tax and accounting advisors regarding these matters. Prio Wealth manages 1,765 discretionary accounts for 692 clients with a total AUM of $3,288,110,373 as of December 31, 2022.