The Adviser is an indirect subsidiary of Canadian Imperial Bank of Commerce (“CIBC”), a Canadian-based financial institution and publicly traded entity. CIBC National Trust Company, a federally chartered limited purpose trust company, CIBC Delaware Trust Company, a Delaware limited-purpose trust company, and the Adviser are wholly owned subsidiaries of CIBC Private Wealth Group, LLC, collectively referred to as CIBC Private Wealth. We provide investment advisory and wealth advisory services. Investment advisory services include asset allocation planning, proprietary investment offerings, portfolio management services, external manager selection and customized reporting. Wealth advisory services include assisting clients with financial, estate and philanthropic planning. We also engage in related business activities, including the licensing of rights to use benchmark indices we develop and maintain. We license our intellectual property rights in such indices to affiliated entities and third parties who create, and issue investment products based on these underlying indices. In such cases, the affiliated entity or third party pay us a licensing fee which represents a portion of the management fee the affiliated entity or third party receives in connection with the associated investment products. As an extension of our wealth advisory services, for an additional fee, we coordinate the provision of specialized administrative services to businesses, estates, and qualified client families. This includes assistance with complex needs such as estate planning, tax planning, charitable giving, wealth distribution, family budgeting, and property management. Through our affiliates CIBC National Trust Company and CIBC Delaware Trust Company, we implement family office services, including consolidated reporting, expense management and family governance structures, utilizing experienced wealth management employees and through partnerships with our clients’ other financial service providers such as certified public accountants, law firms and trust companies. Sometimes these third-party firms have an existing relationship with the client or are appointed by the client upon our recommendation. In such circumstances, the Adviser receives no financial compensation from the firms it recommends. Our Relationship Managers work with our clients to customize investment strategies. Clients can choose the level of contact with their Relationship Manager, but the Relationship Manager will generally communicate with their clients at least annually. Further, on an annual basis, the Relationship Manager will review the investment objective for each account over which the Adviser exercises investment discretion. At the client’s direction, the investment strategy will be an overall asset allocation model or serve as a portion of a broader asset allocation model. The strategy is designed using a custom portfolio, a portfolio of internally and/or externally managed strategies, or a combination of both. Clients can impose reasonable restrictions on their investments; for example, clients can exclude or restrict specific securities and/or certain industries or types of securities. Restrictions imposed are input in our internal systems in the form of trading rules that are specific to a client’s account to ensure that client requirements are adhered to when trades are placed for an account. We provide discretionary and nondiscretionary investment advice to separately managed accounts. We also advise “wrap fee” programs and platforms sponsored by investment advisers, broker-dealers, and other financial service firms (Program Sponsors) either directly to the Program Sponsor (Single Contract SMA) or the participants (Dual Contract SMA) depending on the program (collectively referred to as SMA Programs). We also provide advice to Program Sponsors and/or overlay managers through model investment portfolios (collectively referred to as the Model Program). Our SMA Program and Model Program are collectively referred to as the (Managed Account Programs). In the Non-Discretionary Model Program, we do not consider ourselves to have an advisory relationship with clients of the Program Sponsor or overlay manager. If this Form ADV Part 2A is delivered to Program Sponsor’s model-based clients with whom we do not have an advisory relationship, or where it is not legally required to be delivered, it is provided for informational purposes only. Program Sponsors are responsible for reviewing their clients’ financial circumstances and investment objectives and determining the suitability of our strategies and the Managed Account Program for their clients (participants). Generally, Program Sponsors are primarily responsible for client contact. Subject to applicable law and fiduciary obligations, we will make reasonably available to Program Sponsors and their clients certain staff who are knowledgeable about the services being provided by us for discussions at the strategy level. Depending

on the strategy, we invest in a variety of securities and other investments and employ different investment techniques. In a Single Contract SMA program, we enter into an investment sub-advisory agreement with a Program Sponsor under which we have investment discretion to manage client assets in the approved strategy. In the Dual Contract SMA program, we enter into an investment advisory agreement directly with clients. Depending on the wrap fee program, services typically include manager selection, custodial services, periodic monitoring of investment managers, performance reporting and trade execution (often without a transaction specific commission or charge), provided by the Program Sponsor, and investment advisory services, provided by an investment manager, for a bundled fee paid to the Program Sponsor. Depending upon the level of the wrap fee charged by a Program Sponsor, the amount of portfolio activity in a participant’s account, the value of the custodial and other services that are provided under a wrap fee program and other factors, a participant should consider that the cost for a wrap fee program account may be more or less than if a participant were to purchase the investment advisory services and the investment products separately. In most wrap fee programs, the Program Sponsor is responsible for ascertaining the financial circumstances, investment objectives, and investment restrictions applicable to each participant through information provided to the Program Sponsor by the participant. We rely on such information provided by Program Sponsor. Clients may select us from among the investment advisers that the Program Sponsors present. Clients are encouraged to consult their own financial advisors and legal and tax professionals on an initial and continuous basis in connection with selecting and engaging the services of an investment manager for a particular strategy and participating in a Managed Account Program. While providing services to Managed Account Program accounts advised by a financial advisor, we generally rely on information or directions communicated by the financial advisor acting with apparent authority on the client’s behalf. We reserve the right, in our sole discretion, to reject for any reason any SMA Program participant referred to it. In the Model Program, we provide model portfolio advice through an agreement with Program Sponsors and/or an overlay manager. We monitor and update the model portfolios on an ongoing basis and will deliver such updates to the Program Sponsor or overlay manager. We have sole discretion for determining the appropriateness, diversification or suitability of securities selected for the model portfolios. Program Sponsors or an overlay manager will provide clients the services described in the Program Sponsor’s or overlay manager’s agreement with such participants, including selection of the investment strategies based on information provided by the participant. We do not provide customized investment advice or recommendations to Model Program participants. No model portfolio is personalized or in any way tailored by us to reflect the personal financial circumstances or investment objectives of any participant. In the Non-Discretionary Model Program, the Program Sponsor retains investment and brokerage discretion and is responsible for investment decisions and performing many other services and functions typically handled by us in a traditional discretionary separate account relationship. In the Discretionary Model Program, we forward investment advice to the overlay manager designated by the Program Sponsor who typically acts on the model advice provided in client accounts considering any client-imposed restrictions accepted by the overlay manager. We do not have brokerage discretion in the Discretionary Model Program and thus have no authority to place orders for the execution of transactions. We are not deemed to be a “sponsor” or a “manager” as those terms are defined in Investment Company Act Rule 3a-4 with respect to the services it provides to Managed Account Programs. We are paid a portion of the fee clients pay to their Program Sponsor on the clients’ behalf. We pay certain sponsors and other third-party platforms to participate in their programs or be listed on their platform. The total fees clients pay under a wrap fee arrangement are determined by the sponsor of the program and are not set by us. For more information on the wrap fee programs in which we participate, see Item 5C below. Most of our clients receive discretionary investment management in which we make investment decisions on their behalf. Other clients receive our services on a non-discretionary basis in which the clients make their own investment decisions. We also provide consulting and/or administrative reporting services on a fixed rate basis. As of December 31, 2023, we had $55,360,779,620 under management on a discretionary basis, and $1,947,769,335 on a non- discretionary basis.