A. First Foundation Advisors (the “Registrant”) is a corporation formed on December 12, 1985 in the State of California. The Registrant became registered as an investment adviser in February 1990. John A. Hakopian is the Registrant’s President. The Registrant is owned by First Foundation Inc. (FFI). FFI’s common stock is publicly traded on the New York Stock Exchange under the symbol “FFWM” and the ownership of that entity will change on a regular basis. B. As discussed below, the Registrant offers to its clients, directly or through one of its affiliated entities, investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES The client can engage Registrant to provide discretionary and/or non-discretionary investment advisory services to individuals, families, businesses, and retirement plans (see below). Before engaging Registrant to provide investment advisory services, clients are required to enter into an agreement with Registrant setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fees that a client will incur (see fee schedule at Item 5 below). Registrant provides investment advisory services specific to the needs of each client. Before providing investment advisory services, Registrant will determine the client’s investment objectives. Registrant will then allocate (or recommend that the client allocate) the assets in a client’s portfolio consistent with their designated investment objectives. To the extent requested by an individual client, Registrant will generally provide financial planning and consulting services. To the extent that the Registrant determines to include financial planning services as part of its advisory services as set forth at Item 5 below, the Registrant’s advisory fee will remain the same regardless of whether or not the client determines to address financial planning issues with Registrant. Regardless, in the event that the client requires extraordinary planning or consultation services, the Registrant may determine to charge a client for such additional services pursuant to a stand- alone written agreement (see Limitations below). ERISA PLAN ENGAGEMENTS: Registrant can be engaged to provide investment advisory services to ERISA retirement plans, where the Registrant manages plan assets consistent with the investment objective designated by the plan sponsor. In such engagements, the Registrant will serve as an investment fiduciary as that term is defined under the Employee Retirement Income Security Act of 1974 (“ERISA”). The Registrant will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Registrant. Registrant may also provide investment advisory services to participant directed retirement plans per the terms and conditions of a Retirement Plan Consulting Agreement between Registrant and the plan. For such engagements, Registrant shall assist the plan with the selection of an investment platform from which plan participants can make their respective investment choices, and, to the extent engaged to do so, may also provide education to assist the participants with their decision- making process. SUB-ADVISED MUTUAL FUNDS AND CONFLICT OF INTEREST: Pursuant to a written sub-advisory agreement, the Registrant serves as a sub-adviser to a registered investment company under the Investment Company Act of 1940. At this time, the Registrant currently serves as a sub-adviser to certain funds advised by Brookmont Capital Management. The Registrant will observe the investment parameters described in the fund’s offering documents as well as those required by the Investment Company Act of 1940. A conflict of interest arises whenever the Registrant has an actual or perceived economic or other incentive in its management of client’s accounts in a way that benefits the Registrant. A conflict is present where we may invest, on a discretionary basis, in a mutual fund where we sub-advise. All else equal, the Registrant has a preference for mutual funds where it serves as sub-adviser. When appropriate, the Registrant’s mutual funds that it sub-advises may be held in client accounts (up to 100%), subject to applicable law and any account-specific considerations. Clients may contact us to elect not to invest in any investment product that we sub-advise by emailing us at [email protected] or contacting Greg Bruce at (949) 476-0300. As discussed above, clients may elect to exclude from their account’s investments in any fund that the Registrant serves as sub-adviser. If a client has already made an investment in a fund that we serve as sub-adviser, and requests selling the fund, they may incur tax consequences because of such election. The Registrant will comply with ERISA and Section 4975 of the Internal Revenue Code for all purchases of mutual funds it sub-advises in Individual Retirement Accounts or in qualified retirement plans subject to ERISA by providing a credit of advisory fees associated with the discretionary management of these funds against the client’s management fee set forth in Item 5 below. A credit of advisory fees associated with the discretionary management of these funds for other nonqualified client accounts will be applied in the same manner as above. The Registrant’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. See Item 5 for a summary of fees associated with the Registrant’s Sub- Adviser services. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent requested by a client, the Registrant may provide financial planning and/or consulting services (including investment and non-investment related matters, such as estate, tax and insurance planning, etc.) on a stand-alone separate hourly rate basis. Registrant’s planning and consulting fees are negotiable, but generally range from negotiable up to $350 on an hourly rate basis, depending upon the scope and complexity of the service(s) required and the professional(s) rendering the service(s). Alternatively, the Registrant may charge a fixed rate for the project with up to 50% of the total fee due at inception and the balance due at the completion of the project depending on the scope of the project. Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, an estimated fee and the portion of the fee that is due from the client prior to Registrant commencing services. If requested by the client, Registrant may recommend the services of outside professionals for additional consulting and/or implementation purposes. The client is under no obligation to engage the services of any such recommended professional. At all times, the engaged unaffiliated licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the quality and competency of the services provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Registrant’s consulting services pursuant to this agreement do not include investment implementation, supervisory, management, or reporting services, nor the regular review or monitoring of the client’s investment portfolio. In the event the client desires the Registrant to provide investment supervisory or management services, such engagement shall be set forth in a separate Investment Advisory Agreement between the Registrant and the client, for which services Registrant shall be paid a separate and additional fee. MISCELLANEOUS Retirement Rollovers. Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. If Registrant provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Registrant is acting as 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. No client is under any obligation to roll over retirement plan assets to an account managed by Registrant, whether it is from an employer’s plan or an existing IRA. Registrant’s Chief Compliance Officer, Greg Bruce, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Limitations of Non-Investment Consulting/Implementation Services. As indicated above, to the extent specifically requested by a client, the Registrant can provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Neither the Registrant, nor any of its representatives, serves as an attorney or accountant, and no portion of the Registrant’s services should be construed as legal or accounting advice. To the extent requested by a client, the Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.), including the Registrant’s insurance affiliate (See disclosure at Item 10.C.2). If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not Registrant, shall be responsible for the quality and competency of the services provided. Clients are responsible for promptly notifying the Registrant if there is ever any change in their financial situation or investment objectives so that the Registrant can review, and if necessary, revise its previous recommendations or services. Independent Managers. Registrant may allocate a portion of a client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objectives. In such situations, the Independent Managers shall have day-to-day responsibility for the active discretionary management of the allocated assets. Registrant shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Registrant shall consider in recommending Independent Managers include the client’s designated investment objectives, and the manager’s management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note: The investment management fee charged by any Independent Managers is separate from, and in addition to, Registrant’s advisory fee as set forth in the fee schedule at Item 5 below. Sub-Advised Engagement. Registrant has engaged Parametric Portfolio Associates LLC ("Parametric") and Russell Investment Management, LLC (“Russell”), both unaffiliated SEC registered investment advisers, as sub-advisers to assist the Registrant with the management of certain client accounts. The client shall be responsible for the payment of Parametric’ s and/or Russell’s fee, together with applicable custodial and transaction fees. ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Greg Bruce, remains available to address any questions regarding the sub-advisory role. Unaffiliated Private Investment Funds. Registrant can also provide investment advice regarding unaffiliated private investment funds. Registrant, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Registrant’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Registrant calculating its investment advisory fee. Registrant’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that Registrant references private investment funds owned by the client on any supplemental account reports prepared by Registrant, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, the client’s advisory fee shall be based upon the value reflected on the report. Conflict of Interest: Registrant may recommend that a client consider investing in a private fund that is associated with another Registrant client. Such a recommendation creates a conflict of interest because the Registrant has an economic incentive to make such recommendation (i.e., as result of the allocation, Registrant will assist an existing individual client from whom it currently earns, and anticipates it will continue to earn, investment advisory fees). If, and when, the Registrant makes such a recommendation, it shall disclose the specific conflict, in writing, at that time. Again, no client is obligated to invest in any private investment fund. Please Also Note: Additional Conflict of Interest: Certain private fund sponsors and/or their principals currently are and/or could become customers of First Foundation Bank (“FFB”) (generally independent of the Registrant’s knowledge) thereby creating a conflict of interest (i.e.,

FFB will benefit if the fund or any of its principals are and/or become FFB customers). Given the affiliated relationship between FFB and the Registrant, the Registrant has an economic incentive to recommend such a fund to its clients. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Greg Bruce, remains available to address any questions regarding the above conflicts of interest. Interval Funds/Risks and Limitations. Where appropriate, Registrant may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct Registrant, in writing, not to employ any or all such strategies for the client’s account. Wrap/Separate Managed Account/UMA program engagements. In the event that Registrant is engaged to provide investment advisory services as part of an unaffiliated wrap- fee program, Registrant will be unable to negotiate commissions and/or transaction costs. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately. If the program is offered on a non-wrap basis, the program sponsor will determine the broker-dealer though which transactions must be effected, and the amount of transaction fees and/or commissions to be charged to the participant investor accounts. Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Registrant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Custodian Charges-Additional Fees: As discussed below at Item 5 and 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Registrant generally recommends that Charles Schwab and Co., Inc. (“Charles Schwab”) serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Charles Schwab charge transaction fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab do not currently charge fees on individual equity transactions, others do). When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐ dealers with whom Registrant and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab). These fees/charges are in addition to Registrant’s investment advisory fee at Item 5 below. Registrant does not receive any portion of these fees/charges. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Greg Bruce, remains available to address any questions that a client or prospective client may have regarding the above. Tradeaway/Prime Broker Fees. As indicated above, relative to its discretionary investment management services, when beneficial to the client, individual equity and/or fixed income transactions may be effected through broker-dealers other than the account custodian, in which event, the client generally will incur both the fee (commission, mark-up/mark-down) charged by the executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account custodian. Use of Mutual Funds and ETFs. While the Registrant may recommend allocating investment assets to mutual funds that are not available directly to the public, the Registrant may also recommend that clients allocate investment assets to publicly available mutual funds and exchange traded funds that the client could obtain without engaging Registrant as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly available mutual funds or exchange traded funds without engaging Registrant as an investment adviser, the client or prospective client would not receive the benefit of Registrant’s initial and ongoing investment management services. Please Note: In addition to Registrant’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). ANY QUESTIONS: Registrant’s Chief Compliance Officer, Greg Bruce, remains available to address any questions that a client or prospective client may have regarding the above. Please Note: Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Registrant does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, Registrant shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a non-discretionary investment advisory basis must be willing to accept that Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Registrant would like to make a transaction for a client’s account, and client is unavailable, Registrant will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Please Note: Cash Positions. Registrant continues to treat cash as an asset class. As such, unless determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Greg Bruce, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:  Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,  Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Registrant does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). Registrant does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Registrant:  by taking the loan rather than liquidating assets in the client’s account, Registrant continues to earn a fee on such Account assets; and,  if the client invests any portion of the loan proceeds in an account to be managed by Registrant, Registrant will receive an advisory fee on the invested amount; and,  if Registrant’s advisory fee is based upon the higher margined account value (see margin disclosure at Item 5 below), Registrant will earn a correspondingly higher advisory fee. This could provide Registrant with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Registrant) will be profitable or equal any specific performance level(s). Cybersecurity Risk. The information technology systems and networks that Registrant and its third-party service providers use to provide services to Registrant’s clients employ various controls that are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and/or result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although the Registrant has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that the Registrant does not control the cybersecurity measures and policies employed by third-party service providers, issuers of securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators and providers. Client Obligations. The Registrant will not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on the information in its possession. Clients are responsible for promptly notifying the Registrant if there is ever any change in their financial situation or investment objectives so that the Registrant can review, and if necessary, revise its previous recommendations or services. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. Registrant does not offer a wrap fee program for its investment advisory services. However, in the past Registrant has served, and in the future, could serve, as a participating investment adviser in certain unaffiliated wrap and managed account fee programs. There is no significant difference between how the Registrant manages wrap fee accounts and non-wrap fee accounts. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Registrant will be unable to negotiate commissions and/or transaction costs. Participation in a wrap program may cost the participant more or less than purchasing such services separately. E. As of December 31, 2023, the Registrant had $5,157,629,079 in assets under management on a discretionary basis and $92,319,061 assets under management on a non-discretionary basis.