Hamilton Capital, LLC (“Hamilton Capital”), a limited liability company, is a SEC-registered investment adviser with its principal place of business in Columbus, Ohio. Hamilton Capital is an independent, fee-only investment advisory firm, founded on October 1, 1997.1 The firm is primarily owned by R. Matthew Hamilton. As of 12/31/2023, across its entire business, Hamilton Capital has approximately $4.2 billion of assets under management, of which $4,072,835,012 is discretionary and $147,022,260 is non-discretionary. Hamilton Capital is structurally and philosophically independent; it tries to be free from conflicts of interest and is dedicated to serving client interests with the highest standards of professional conduct. Hamilton Capital believes this independence is central to providing objective and high-quality advice to its clients. To strengthen its commitment to independence, the firm has adopted a Code of Ethics and Standards of Conduct. Fiduciary Status Hamilton Capital provides investment management services in a fiduciary capacity under, and subject to being deemed a fiduciary under the Investment Advisers Act of 1940, the Employee Retirement Income Security Act of 1974 (“ERISA”), and such other governing laws as may apply within any client relationship. SERVICES PROVIDED This Part 2A of Form ADV describes services provided to institutional clients primarily. References to client throughout this Part 2A of Form ADV refer to Hamilton Capital’s institutional clients unless the context requires otherwise. A separate Part 2A of Form ADV describes services provided to Wealth Management and Investment Management clients. Hamilton provides discretionary asset management and investment consulting services (discretionary and non-discretionary). The primary clients for these services are institutions – Endowments, Foundations, Healthcare Organizations, Family Offices, Retirement Plan Sponsors and Consultants, and Financial Advisors and Intermediaries. Institutional Consulting [Traditional and Outsourced Chief Investment Officer (OCIO) Services] Investment management is at the core of almost every service Hamilton Capital provides. Hamilton Capital generally delivers fiduciary oversight and advice under the following process. First, Hamilton Capital assists in the development, implementation, and monitoring of Investment Policy Statements (IPS) for clients. An IPS is a set of standards that prescribes how client assets will be invested, monitored, and measured. These standards begin with articulation of investment objectives; what a client expects to achieve with its assets. The IPS also establishes guidelines for the way funds are to be invested in various asset classes and how performance will be measured and compared. In working with clients to develop their IPS, Hamilton Capital addresses client time horizons, spending needs, liabilities, risk tolerance and 1As of July 1, 2019, Hamilton Capital Management, Inc. underwent an internal organization that resulted in its business operations being assigned to Hamilton Capital, LLC. There was not any practical change in control or management at that time. pg. 4 impact investing objectives. Hamilton Capital then prepares a written IPS detailing those needs and goals, including an encompassing plan under which these goals are to be achieved. Second, Hamilton Capital assists clients in identifying a strategic asset allocation tailored to meet objectives given their constraints and risk considerations. Portfolios are then constructed using the IPS and firm’s criteria for selection of investment vehicles. Third, Hamilton Capital monitors client investments continuously, based on the procedures and timing intervals delineated in the IPS and Hamilton Capital’s internal processes. Hamilton Capital can engage a client in two ways: 1) in a traditional consulting capacity in which Hamilton Capital supervises the client’s portfolio and seeks approval for recommendations before implementation 2) under our OCIO Discretionary Service where Hamilton Capital supervises client portfolios and is delegated discretionary authority for portfolio implementation. Last, Hamilton Capital creates clear and accurate periodic reports, including Quarterly Performance Reports and Special Reports on topics relevant to the client. Hamilton Capital serves its institutional clients utilizing the Investment Metrics reporting system to ensure timely and accurate information and provide robust portfolio analysis and peer group benchmarking for Hamilton Capital clients. Hamilton Capital believes the disciplines it has developed for the institutional marketplace – portfolio analytics, manager research, aggregation of information and clear reporting – are applicable and valuable to families and individuals. The services that Hamilton Capital agrees to provide to a client are documented in a written agreement between the client and Hamilton Capital. Collective Investment Funds We serve as the investment advisor to various collective investment funds (the “Hamilton Capital CIFs”) (each reflecting a different investment strategy) sponsored by Hand Benefits & Trust Company (“HB&T”), a national leader in collective trust administration with nearly $90 billion in investment assets. HB&T is owned by Community Bank System, Inc., which is listed on the New York Stock Exchange (Symbol: CBU). A CIF is a pooled investment vehicle specifically designed for retirement plans. It combines the resources of multiple qualified plans with similar investment objectives to gain economies of scale, including lower investment costs. A CIF is sponsored and administered by a bank or trust company. It is a separate legal entity, operating in the form of a trust that is heavily regulated by the Office of the Comptroller of the Currency or state banking regulators. HB&T is a fiduciary under 3(38) of ERISA and will serve as the fund’s trustee. Specifically, they monitor Hamilton Capital’s compliance with fund investment policies and are responsible for all fund administration including regulatory compliance, fund accounting, unit pricing, performance calculations and reporting, as well as arranging for an annual audit of fund assets. Legal responsibility for all investment management decisions remains with Hamilton Capital. pg. 5 Retirement Plan Services – ERISA 3(21) and 3(38) Fiduciary Services Hamilton Capital offers retirement plan services to employee benefit plans, including but not limited to 401(k), 403(b), 457, Money Purchase Plans, Cash Balance Plans, Defined Benefit Pension Plans, and the plan sponsors based upon an analysis of the needs of the plan. The “plan sponsor” or the plan itself is our client and not any plan participant or beneficiary of a plan. Hamilton Capital’s serves as the Plan’s fiduciary and investment manager as defined under sections 3(21) and 3(38) of ERISA. In addition, Hamilton Capital can perform an existing plan review, plan design consulting, vendor search, formation of an IPS, fund menu design, investment performance monitoring, investment performance reporting, investment committee formation and guidance, selection of Qualified Default Investment Alternative (QDIA), support with section 404(c) compliance, education services to the plan committee and/or communication and education services where Hamilton Capital can assist the client in providing meaningful information

regarding the retirement plan to its participants. The educational support does NOT provide plan participants with individualized, tailored investment advice unless specifically retained to do so. Affiliated Funds - The Dynamic Alternatives Fund Hamilton Capital also serves as investment adviser to the Dynamic Alternatives Fund. For additional information about the Dynamic Alternative Fund, including fees, expenses, and risk factors, please see the Fund’s Prospectus and Statement of Additional Information. Those documents are available online at the SEC’s website (http://www.sec.gov). Hamilton Capital’s clients are under absolutely no obligation to consider or make an investment in any affiliated investment fund(s). HCRE Edge, LLC For clients that are accredited investors and qualified clients (as those terms are defined under federal securities law), Hamilton Capital may recommend an investment in an affiliated private investment fund— the HCRE Edge, LLC (the “affiliated private fund”). Hamilton Capital serves as the manager of the affiliated private fund. Hamilton Capital treats the affiliated private fund as subject to its policies and procedures and all the substantive provisions of the Investment Advisers Act of 1940, as amended. The terms and conditions of investing in the affiliated private fund, including management fees, conflicts of interest, and risk factors, are set forth in the affiliated private fund’s offering documents. Hamilton Capital stands to earn compensation from the affiliated private fund. This relationship creates a conflict of interest. Hamilton Capital seeks to mitigate this conflict of interest by (1) disclosing it to clients and prospective clients, and (2) generally seeking to recommend the affiliated private fund to investors that such an investment may be appropriate. Additionally, clients will not incur both management fees of the affiliated private fund and Hamilton Capital’s asset-based investment management fee. They will only incur the management fees of the affiliated private fund. Nonetheless, Hamilton Capital may favor the affiliated private fund over other unaffiliated private funds with comparable investment objectives and strategies. For more information, see Items 5 and 10. Unaffiliated Private Funds Hamilton Capital may also provide investment advice regarding private investment funds. Hamilton Capital, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts, and fees, including incentive compensation) is set forth in the fund’s offering documents. Hamilton Capital’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Hamilton Capital calculating its investment advisory fee. Hamilton Capital’s fee shall be in addition to the fund’s fees. pg. 6 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. In the event that Hamilton Capital references private investment funds owned by the client on any supplemental account reports prepared by Hamilton Capital, 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 in the report until the fund provides a further updated value. Please Also Note: 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, Hamilton Capital shall calculate its fee based upon the latest value provided by the fund sponsor. Independent Managers Hamilton Capital may allocate a portion of the client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to- day responsibility for the active discretionary management of the allocated assets. Hamilton Capital 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 that Hamilton Capital shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note. The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, Hamilton Capital’s investment advisory fee disclosed at Item 5 below. FAIR – Fiduciary Audit Independent Review Hamilton Capital’s Fiduciary Audit Independent Review (FAIR) service seeks to provide the transparency necessary for institutional investors to evaluate the effectiveness of their Outsourced Chief Investment Officer (OCIO). This fiduciary oversight program is designed to deliver protection and excellence in investment plan management through independent governance and monitoring. The FAIR service provides analysis and feedback on OCIO performance to help board members protect the future success of their institution by conducting an in-depth analysis of the process and procedures of the OCIO provider. This includes an examination of investment returns (gross and net of fees) and risks relative to the client investment objectives and compared to a customized peer group of investors of similar size and purpose. FAIR evaluates all costs associated with the investment program and compares those with industry norms as we see them. pg. 7 Hamilton Capital has a conflict of interest because, as Hamilton Capital also provides Discretionary OCIO (investment management) services, the Firm may be incentivized to recommend changes that could lead to the Client implementing changes to its investment managers, including the hiring of Hamilton Capital to manage assets.