HH provides investment management, wealth advisory, financial planning, and consulting services. Prior to engaging HH to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with HH setting forth the terms and conditions under which HH renders its services (collectively the “Agreement”). HH has been in business as an SEC registered investment adviser since October 13, 1988. Halbert Hargrove Holdings, LLC, is the principal owner of HH. HH has $3,162,314,796 of assets under management as of December 31, 2023. $3,010,656,083 of these assets are managed on a discretionary basis and $151,658,713 are managed on a non-discretionary basis. This Disclosure Brochure describes the business of HH. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of HH’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on HH’s behalf and is subject to HH’s supervision or control. Wealth Advisory and Financial Planning Services HH can be engaged to provide its clients with a broad range of wealth advisory and financial planning services. A primary focus of HH is providing wealth advisory and financial planning services to individuals and families. Advice is rendered in the areas of cash flow and debt management, risk management, college funding, retirement planning, estate planning, investment tax planning, asset allocation, investment selection, intergenerational wealth planning and charitable gifting. In performing its services, HH is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. HH can recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if HH recommends its own services. Clients are advised that it remains their responsibility to promptly notify HH if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising HH’s previous recommendations and/or services. Consulting Services HH also provides consulting services on a non-discretionary basis for clients. HH’s consulting team specializes in manager and broad market research, due diligence, asset allocation and portfolio monitoring, analysis, and reporting. The client is under no obligation to act upon any of the recommendations made by HH under a separate consulting engagement or to engage the services of any such recommended professional, including HH Page 5 © MarketCounsel 2024 itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of HH’s recommendations. Investment Management Services Clients can engage HH to manage all or a portion of their assets on a discretionary basis. Wealth advisory services are typically provided as a bundled service for discretionary accounts. Non- discretionary accounts may be considered. HH primarily allocates clients’ investment management assets among Independent Managers (as defined below), mutual funds (including closed-end funds such as interval funds and tender offer funds), exchange-traded funds (“ETFs”), structured products, and individual debt and equity securities in accordance with the investment objectives of the client. The Firm also recommends that certain clients invest in tender offer funds and privately placed securities (including debt, equity and/or pooled investment vehicles) that are limited to “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, and/or “qualified purchasers” as defined under the Investment Company Act of 1940, as amended, and/or “qualified clients” as defined under the Investment Advisers Act of 1940. In addition, HH can recommend to clients a socially responsible investing solution that integrates multiple strategies to balance risk, return, and positive social impact when consistent with the client’s investment objectives. HH also provides advice to certain clients about other investments held in clients' portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. HH also renders non-discretionary investment management services to clients relative to variable life/annuity products that they own, their individual employer-sponsored retirement plans, or other products that are not be held by the client’s primary custodian. In so doing, HH either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. HH tailors its advisory services to the individual needs of clients. HH consults with clients initially and on an ongoing basis to develop an investment policy statement based on the client’s needs, risk tolerance, time horizon and other factors. HH attempts to match clients’ investments with their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify HH if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon HH’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in HH’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Page 6 © MarketCounsel 2024 Use of Independent Managers As mentioned above, HH generally recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client

engages the Independent Managers are set forth in a separate written agreement between HH or the client and the designated Independent Managers. HH renders services to the client relative to the discretionary recommendation or selection of Independent Managers. HH also monitors and reviews the account performance and the client’s investment objectives. HH receives an annual advisory fee from the client which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When selecting an Independent Manager for a client, HH reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that HH considers in recommending an Independent Manager include the client’s stated investment objectives, the manager’s management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, HH’s investment advisory fee set forth below. As discussed above, the client will incur additional fees to those charged by HH, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to HH’s written disclosure brochure, the written disclosure brochure of the designated Independent Managers, or current prospectus in the case of mutual funds and certain other investment products, is available. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than HH. In such instances, HH may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Retirement Asset Disclosures The following discussion is limited to the Firm’s services to retirement assets subject to ERISA or the Internal Revenue Code. Fiduciary Acknowledgment When HH provides investment advice to clients regarding their retirement plan account or individual retirement account, HH is a fiduciary 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 HH makes money creates some conflicts with client interests, so HH operates under a special rule that requires it to act in the client’s best interest and not put HH's interest ahead of the clients. Page 7 © MarketCounsel 2024 Under this special rule’s provisions, HH must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put HH's financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that HH gives advice that is in the client’s best interest;
• Charge no more than is reasonable for HH's services; and
• Give clients basic information about conflicts of interest. Conflict of Interest: Rollover Recommendation As discussed in this Disclosure Brochure and HH's Relationship Summary, the way HH makes money creates some conflicts with client interests. A conflict of interest exists when HH recommends its own services. Additionally, HH's financial professionals are compensated based on revenue the Firm earns from the financial professional’s advisory services or recommendations, which creates a conflict of interest. The compensation results in an incentive to take steps to maximize revenue to the Firm by increasing the size of the client’s account and/or relationship with HH. Therefore, a Rollover Recommendation creates a conflict of interest by recommending HH’s own services and increasing the size of the client’s account and/or relationship with HH. A Rollover Recommendation includes the following: (i) rollover from plan-to-IRA, (ii) transfer of an IRA from another financial institution, (iii) rollover from a plan-to-plan, and (iv) rollover from an IRA-to-plan. Development of Rollover Recommendation from plan-to-IRA In order to develop a recommendation that is in the client’s best interest, HH needs to consider information about the client’s plan’s investments, services and expenses. As a result, it is important that client provides HH with actual information about the plan and account. The easiest way to do that is for the client to give HH copies of the plan’s 404a-5 investment disclosures and of a recent quarterly statement about the account. (The plan gives clients a “404a-5 disclosure” every year and a copy is available from the client’s employer and the plan’s website. It is also called by a number of other names, for example, Investment Comparative Chart, and it is a description of the plan’s investment options and their expenses, and other information.) If client does not give HH that information, the Firm will need to use estimates or other information that may not be accurate and that could, as a result, cause HH to make a recommendation that may not properly represent that actual facts or preferred outcome. So, it is in client’s interest to make sure that HH has the actual plan information. Page 8 © MarketCounsel 2024 However, if client does not provide the information, HH will use alternative sources, such as benchmarking data for plans of a similar type and size or plan reports (such as Forms 5500) that may be from several years ago. In evaluating possible sources of alternative data, HH has considered the reliability of the data provider and its processes, and believes that the information that the Firm will use will be accurate based on, e.g., robust information about plans of the size and type of client’s plan. While HH expects that it will be accurately representative of client’s plan’s features, there can and will be differences which could affect the Firm’s recommendation.