Ingalls & Snyder, LLC (“Ingalls & Snyder” or the “Firm”) was founded in 1924 and became registered as an investment adviser in 1968. The Firm provides investment advice to individuals, banks and other financial institutions, pension and profit-sharing plans, trusts and estates, charitable organizations, corporations and private investment entities. The Firm is a limited liability company organized under the laws of the State of New York. The Firm is beneficially owned by senior professionals of the Firm and is not publicly traded. For the most part, each of the Firm’s investment adviser representatives offers a distinct asset management style that is based upon, among other things, the research that the investment adviser representative conducts regarding issuers of securities and the market for securities. Each investment adviser representative manages his or her accounts on a discretionary basis in accordance with his or her management style. As a result, one or more investment adviser representatives may determine to acquire a security for particular advisory accounts while other investment adviser representatives may determine to dispose of the same security for advisory accounts which they manage on a discretionary basis. While each of the Firm’s investment adviser representatives tend to manage accounts in accordance with an individual style, each investment adviser representative adapts his or her style based on the individual needs of his or her clients. Accordingly, the Firm seeks to achieve investment advice for each client that is suitable for his or her needs and risk tolerance. In addition to portfolio management, the Firm also provides financial planning services primarily involving asset allocation and third-party manager selection for clients. Ingalls & Snyder also provides investment advice to various private investment partnerships, including Ingalls & Snyder Value Partners L.P., Underhill Partners L.P., and IAS Alpha Partners LP (“Limited Partnerships”). Ingalls & Snyder also serves as an investment adviser in one or more “wrap” programs that are offered by third-party wrap program sponsors (typically broker-dealers).

A wrap program is an investment advisory program under which a client typically pays a single fee to the sponsor based on assets under management. Fees paid are not based directly upon transactions in the client’s account or the execution of client transactions. Wrap program clients typically select Ingalls & Snyder from a list of investment advisers presented to clients by registered representatives of the sponsor. Wrap program clients are typically high net worth individuals. The program sponsor has primary responsibility for client communications and service, and Ingalls & Snyder provides investment management services to the clients. The program sponsor typically executes client’s portfolio transactions, and in most cases, provides custodial services for the client’s assets for a single fee paid by the client to the sponsor. Ingalls & Snyder is paid a portion of the wrap fee (management fee) for its services by the program sponsor. Ingalls provides portfolio consulting services to certain Unit Investment Trusts. Ingalls & Snyder acts as a portfolio consultant to Hennion & Walsh, Inc. in connection with its SmartTrust ® Fundamental Equity Contrarians Trust (the “Trust”). The Trust seeks a total return potential through capital appreciation and dividend income. The securities selected are those with solid operating fundamentals but not universally favored by Wall Street analysts. Each series of the Trust is designed to be held over a fixed 15-month term. Ingalls offers a Donor Advised Fund Program that enables clients to establish a charitable giving account (“DAF”). All contributions into a DAF are irrevocable and non-refundable. - All investment-related expenses are assessed from the DAF assets which include investment management fees, administrative fees, mutual fund or ETF expenses, withholding taxes on offshore income, and trading costs. Please review the GiveClear Donor Advised Fund Program Guidelines and the Management Fee Schedule for more information regarding the fees applicable to DAFs. As of September 30, 2023, Ingalls & Snyder manages $5,079,714,740 on a discretionary basis and $153,141,419 on a non-discretionary basis.