Welch Capital Partners, LLC (“WCP” or the “Firm”), formed in 1996, emphasizes providing long-term after-tax wealth creation through the buying of a portfolio of equity securities and sourcing venture capital and private equity fund managers. The Firm's investment style is to seek undervalued growth. WCP manages clients’ assets through separately managed accounts (“SMA”) or a long-short private limited partnership. In addition, WCP may provide advice to its clients regarding direct investments in third-party venture capital and/or private equity funds (“third-party private funds”). Clients with SMAs can have their portfolios tailored for specific risk tolerances and/or sector weightings. When WCP advises its client(s) on direct investments in a third-party private fund(s), either exclusively, or alongside their SMA, the client does so at their own discretion. WCP seeks out first-class, third-party private fund managers that are actively raising venture capital or private equity funds. When WCP deems a fund investment to be suitable for its client(s), it presents the fund investment to the client(s). The client(s) will ultimately decide, through consultation with WCP, whether to invest in the third-party private fund and the appropriate size of the investment. The principals of WCP, and the individuals who determine general investment advice to be given to clients, are Leighton B. Welch and Christopher W. Welch. Mr. Leighton B. Welch was born in 1961. He holds an A.B. from Harvard College (1983) and an M.B.A. from Harvard Business School (1989). From May 1991 to December 1994, he was a Research Analyst at Eagle Capital Management

Corp., an investment advisory firm. From December l994 until the commencement of the business of WCP, he was a Portfolio Manager at Eagle Capital Management Corp. Mr. Christopher W. Welch was born in 1965. He holds an A.B. from Harvard College (1988) and an M.B.A. from Harvard Business School (1994). From July 1988 to June 1991, he was an Analyst at Smith Barney Harris Upham & Co. in the Investment Banking Division. From 1994 until joining WCP, he was a Portfolio Manager at Bankers Trust Company. WCP provides investment advisory services to SMAs as well as Welch Entrepreneurial Fund, L.P. (the “Fund”), a limited partnership for which Welch Fund Management, LLC acts as general partner. Leighton B. Welch and Christopher W. Welch are the Managing Members of Welch Fund Management, LLC. WCP also advises its clients on direct investments in third-party private funds. The client makes the investment either directly from the client’s SMA or from a source that is unaffiliated with WCP. As of December 31, 2023, WCP had approximately $585.9 million in assets under management, of which $398.6 million were regulatory assets under management, managed on a discretionary basis, and $187.3 million were managed on a non-discretionary basis. Of the $187.3 million managed on a non-discretionary basis, approximately $33.7 million were attributable to the ten non-discretionary clients for whom WCP does not have regulatory assets under management, as reported in Item 5.C.(1) of Form ADV Part 1 and approximately $153.6 million (of assets not constituting regulatory assets under management) were attributable to clients that have an existing discretionary account(s) with WCP.