Description of Advisory Firm Apriem Advisors (also “we” or “us”) is a privately-owned corporation headquartered in Irvine, California. Founded by Mark K. Iwamoto and Harmon A. Kong, Apriem Advisors has been providing investment advisory services since 1998. Apriem Advisors is registered as an investment adviser with the U.S. Securities and Exchange Commission. The firm’s principal owners are Harmon Kong, Rhonda Ducote, and Benjamin Lau. There are two additional principals who collectively own under 11% of Apriem Advisors. Advisory Services Offered Wealth Management Services Apriem Advisors offers wealth management services primarily to high-net-worth and ultra-high net worth individuals and families. Typically, our clients are seeking not just money management but comprehensive wealth planning. Through Apriem Advisors’ wealth management services, we work with clients to get a holistic overview of their financial picture to create a customized wealth management approach. Our wealth management services include advanced or comprehensive financial planning, implementation of the client’s investment plan through investment management utilizing customized portfolios as well as the availability of Apriem Total View, an online financial tracking system that allows our clients to consolidate their total financial picture. Minimum account requirements are discussed under Item 7 – Types of Clients. Customized Portfolios Once we have determined the overall investment approach for the client, we design, monitor, and evaluate the client’s investment portfolio. The customized portfolios we build are tailored to address the client’s unique financial needs and preferences. Asset allocations and client portfolio performance may differ even among clients with similar risk tolerance and objectives. Charitable Services Apriem Charitable serves as your partner in philanthropy. We serve 501(c)(3) non-profit organizations through providing investment management and financial advice for their cash reserve portfolios and endowments. Portfolios are managed based on the client’s investment objectives, annual distribution requirements, and unique legal considerations. We will also be available for quarterly meetings with the Board of Directors and/or the Investment Committee. Retirement Plan Services Apriem Retirement Plan Services provides investment-related services to the Plan as a fiduciary within the meaning of Section 3(21) of ERISA. We assist Plan Sponsors with a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder; monitor investment options; provide Apriem Advisors Brochure 6 investment advice on a regular basis pursuant to a mutual agreement with the Plan or a Plan fiduciary where the advice will serve as a primary basis for investment decisions with respect to plan assets and will be individualized based on the particular needs of a plan. For Plan Participants, we provide investment education, conduct enrollment meetings explaining the benefits of Plan participation, investment objectives of Plan, investment options, as well as general financial and investment information. Foundational Asset Management Foundational Asset Management (FAM) helps those who are in the accumulation phase of their life and seeking a blended approach between hands-on financial advice and a Robo-Advisor. It is a personalized portfolio management service and expertise in an automated, modern, digital client experience. It features streamlined client onboarding, automated rebalancing, and optional tax-loss harvesting. We offer Foundational Financial Planning that answers expense/goals-based questions to help clients prepare to begin their investment journey. This is our only offering that has phone-only or Zoom-only access to our live CFP® professionals. Minimum account requirements are discussed under Item 7 – Types of Clients. External Account Management External Account Management provides an additional service for “held-away” accounts including 401(k), 403(b), TSP, 401(a), 457(b), 529 plan, Health Savings Account (HSA). We use a third-party Order Management System to facilitate discretionary management to implement asset allocation and opportunistic rebalancing strategies on behalf of the client. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in order to help the client achieve their overall financial objective. Client account(s) will be reviewed at least quarterly, and changes will be made as deemed necessary. Minimum account requirements are discussed under Item 7 – Types of Clients. Enhanced Cash Management Enhanced Cash Management provides an additional layer of income and stability using a portfolio of individual short-term government bonds, investment grade bonds, or municipal bonds. We use a third- party Subadvisor to manage the account in accordance with Client’s overall financial goal. Accounts will be managed on a discretionary basis to implement tax-efficient fixed income strategies based on factors such as Client’s financial profile, tax position, liquidity requirements. Accounts will be reviewed at least quarterly and changes will be made as deemed necessary. Please see item 5 “other fees” for an explanation of other fees related to this service. Apriem Advisors Brochure 7 Direct Indexing Strategies Direct Indexing Strategies provide long-term capital appreciation by buying a "custom" index. We use a third-party Subadvisor to manage the account in accordance with Client’s overall financial goal. Accounts will be managed on a discretionary basis to implement tax-efficient strategies based on factors such as Client’s financial profile, tax position, liquidity requirements. Accounts will be reviewed at least quarterly and changes will be made as deemed necessary. Please see item 5 “other fees” below for an explanation of other fees related to this service. Financial Planning Services Financial Planning Services is a fee-only service that provides a general overview of a client’s financial snapshot plus financial planning advice that may focus on one or a combination of objectives, depending on the package that Client chooses: Tier 1: This is our top tier financial planning service which provides customized financial planning for more complex estates and in-depth analysis on many facets of the client’s financial situation. Client gets up to eight meetings with a CFP® Professional, including up to two meetings with Client and their personal CPA/Attorney. It also includes 24/7 Access to Online Financial Planning Portal. Specialized Financial Planning covers any of the following objectives:
• Irrevocable/Sub-Trust Estate Planning
• Family Limited Partnerships
• DST & Capital Gains Minimization
• Highly Concentrated Stock Strategy
• Buy Sell Insurance Analysis
• Charitable Trust Planning
• Business Succession Planning
• Advanced Tax Simulations
• Premium Financing Strategies
• Executive Compensation Strategies
• Private Equity/Venture Capital Planning
• Philanthropic and Impact Investing
• Multi-Generational Meetings & Planning
• Tax Efficient Gifting Strategies
• Employer Based Retirement Analysis
• Deferred Compensation Planning
• Defined Benefit Planning
• Any of the objectives from the Tiers 2, 3, and 4 Tier 2: Tier 2 provides a comprehensive overview of many facets of a client’s financial situation. Client gets up to four meetings with a CFP® Professional covering up to twenty-five of the following objectives:
• Pension Analysis
• Net Unrealized Appreciation
• Estate Plan Flowchart
• 1031 Exchange Analysis
• Self-Employed Income Strategies
• Holistic Tax Return Analysis
• Backdoor Roth
• Next Generation Support
• Inherited IRA RMD Planning
• RMD Management Apriem Advisors Brochure

8
• Advanced Trust and Estate Planning
• Tax-Loss Harvesting Analysis
• Tax Planning for Self-Employed
• Small Business Retirement Plans
• Stock Option Analysis
• Any of the objectives from Tiers 3 and 4 Tier 3: Tier 3 offers more time with a CFP® Professional and recommendations on more advanced, dynamic financial planning topics. Client gets up to three meetings with a CFP® Professional covering up to ten of the following objectives:
• Buying Investment Properties
• Mortgage Analysis
• Long-Term Care Analysis
• Existing Insurance Policy Review
• College Education Planning
• Alternative State Tax Domicile
• Charitable Gifting/Donor Advised Fund
• Capital Gains Budgeting
• Roth Conversions
• Asset Location Recommendations
• Health Insurance Planning
• Tax-Efficient Investment Strategies
• Basic Estate Planning Analysis
• Investment Planning for Minors
• Retirement Income Planning
• F.I.R.E. Strategies
• Any of the objectives from Tier 4 Tier 4: It provides a general overview of a client’s financial snapshot, advice, and recommendations to general personal finance-related inquiries. Client gets up to two meetings with a member of the Financial Planning Team covering up to four of the following objectives:
• Emergency Fund Planning
• Creating a Long-Term Savings Plan
• Credit Score Analysis
• Buying A Primary Home
• Asset Allocation Analysis
• Retirement Date Planning
• Paying Off Consumer Debt
• Life Insurance Needs Analysis
• Long Term Tax Projections
• Budget Analysis
• Social Security Optimization
• Risk Tolerance vs Risk Capacity Our financial planning services do not include preparation of any kind of income tax, gift, or estate tax returns or preparation of any legal documents, including wills or trusts. However, we may work together with clients’ CPAs and attorneys to coordinate services for the client. Apriem Advisors is a licensed insurance agency and does receive commissions on the sale of insurance products purchased by clients. For more information about these fees, please see Other Compensation We Receive in Item 5 below. Apriem Advisors Brochure 9 Investment Advice Depending on the client’s account strategy, we typically use the following types of securities in our ongoing management:
• Equity securities, such as stocks and foreign securities listed on US exchanges (ADRs)
• Fixed income securities, such as corporate and government bonds, preferred stocks, and TIPS
• Exchange traded funds (ETFs), open-end investment companies (mutual funds), exchange traded notes (ETNs), and closed-end investment companies
• Alternative investments, such as commodity funds, gold funds, inverse ETFs and other funds (leveraged and unleveraged), real estate investment funds, and registered hedge funds (upon additional discussion with the client)
• Money market funds and cash Apriem Advisors will offer investment advice on investments held by the client at the start of an advisory relationship. We also occasionally offer advice regarding additional types of investments if they are appropriate to address the individual needs, goals, and objectives of the client or in response to client inquiry. We describe the material investment risks for many of the securities that we recommend under the heading Specific Security Risks in Item 8 below. We discuss our discretionary authority below under Item 16 - Investment Discretion. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below. Limitations on Investments In some circumstances, Apriem Advisors’ advice is limited to certain types of securities. For example, when we provide services to participants in an employer-sponsored plan, the participant may be limited to investing in securities included in the plan’s investment options. Therefore, Apriem Advisors can only select investments from among the available options, and will not recommend other securities, even if we believe there may be better options elsewhere. Similarly, if Apriem Advisors is managing assets within an annuity, Apriem Advisors is limited to those investment options made available by the insurance company. Tailored Services and Client Imposed Restrictions We believe every client is unique. Each has highly individual preferences, resources, and challenges. Therefore, we begin every client relationship by getting to know the client, so that we can better understand their financial circumstances. Only then can we develop an investment strategy and wealth management approach that is specifically suited to our clients’ needs. Apriem Advisors manages client accounts based on the investment strategies discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. We apply the strategy for each client, based on the client’s individual circumstances and financial situation. We make investment decisions for clients based on Apriem Advisors Brochure 10 information the client supplies about their financial situation, goals, and risk tolerance. Our recommendations may not be suitable if the client does not provide us with accurate and complete information. It is the client’s responsibility to keep Apriem Advisors informed of any changes to their investment objectives or restrictions. For certain clients or groups of clients, Apriem Advisors may implement trading platforms and strategies tailored specifically to these client groups. For example, clients who seek more aggressive trading strategies may be grouped together, as well as clients who only want equities in their portfolios. In addition, we recognize that the Wealth Manager working with a particular client has unique insight into the appropriate investment decisions to be made for that client’s account. While Apriem Advisors’ investment team generally selects and manages client portfolios, the Wealth Managers are consulted with respect to the objectives and restrictions of their clients’ accounts and may, in their discretion, elect not to participate in certain securities investments for some or all of their clients’ accounts. Clients may also request other restrictions on the account, such as when a client needs to keep a minimum level of cash in the account or does not want us to buy or sell certain specific securities. We reserve the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Retirement Account Advice When we provide non-discretionary investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The receipt of our advisory fee for making a recommendation creates a conflict of interest under ERISA/IRC with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. For example, if we recommend that you rollover assets from one retirement account to another and we will receive increased compensation as a result of that recommendation, we have a conflict that requires us to operate under this special rule. Assets Under Management and Advisement As of 12/31/2023: Regulatory Assets Under Management (RAUM) Discretionary Assets $ 1,040,743,172 Non-Discretionary Assets $ 8,931,297 Total RAUM $ 1,049,674,469 Assets Under Advisement $ 399,616 Total Assets $ 1,050,074,085 Apriem Advisors Brochure 11