Introduction MAI is an investment adviser registered with the SEC and headquartered in Cleveland, Ohio. The Firm was initially established as Investment Advisors International, Inc. ("IAI") in 1973 and was an affiliate of International Management Group ("IMG"). In 2000, McCormack Advisors International, LLC ("McCormack") was formed to succeed IAI's business as a joint venture between IAI and a major integrated financial institution. In 2002, the joint venture was dissolved, and the Firm returned to its roots as a provider of independent financial advice to clients. McCormack became fully independent of IMG in 2004. In January 2007, BC Investment Partners, LLC acquired McCormack and renamed the merged firm MAI Wealth Advisors, LLC. In October 2014, the Firm was renamed MAI Capital Management, LLC. Until September 30, 2021, MAI was controlled by its Managing Partner, Richard J. Buoncore. On September 30, 2021, MAI became a subsidiary of MAI Capital Management Intermediate LLC and an indirect subsidiary of MAI Capital Management Holdings LLC ("MAI Holdings"). MAI Holdings is a majority-owned indirect subsidiary of Galway Series 2 Aggregator LP. Mr. Buoncore continues as Managing Partner and CEO of MAI and a board member of MAI Holdings. MAI provides investment and wealth management advisory services, and non-advisory services, to individuals, high-net-worth individuals and families, and institutions. These services include: (1) selecting and reviewing independent investment managers, and (2) reporting investments held or managed by MAI and assets held by outside parties. Advisory and Related Services Investment Management Services MAI provides discretionary and non-discretionary investment management to individuals, high-net-worth individuals and families, and institutions. Services include: x assisting the client with the establishment of their investment objectives and investment policy statement; x buying and selling securities such as stocks, bonds, mutual funds, exchange-traded funds and private and public limited partnerships, and x reporting holdings, transactions, and performance on the client's investment portfolio. MAI also assists clients with developing their asset allocation strategy, portfolio manager selection, managed account programs, and advice concerning outside holdings. We discuss our discretionary authority below under Item 16 - Investment Discretion. For information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below. We describe the Fees charged for investment management services below under Item 5 – Fees and Compensation. Client portfolio management is customized, subject to the client's experience and comfort with particular investment strategies, classes, and products, as well as the discretion portfolio and wealth managers are given to manage client portfolios, their experience, and their investment background. MAI Capital Management, LLC 7 Clients, as applicable, can also access selected investment management services through certain unaffiliated third parties under a sub-advisory relationship. These services are offered on unified managed account platforms or as separately managed accounts in MAI’s investment strategies, as described below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. The fees MAI receives under these arrangements are described below under Item 5 - Fees and Compensation. Wrap Fee Programs MAI also manages a limited number of accounts in wrap fee programs sponsored by other financial services firms. MAI is involved in wrap fee accounts through dual contract arrangements with Stifel, Nicolaus & Company, Inc., and RBC Wealth Management. The client signs an agreement with an unaffiliated broker-dealer and MAI in a dual contract arrangement. The client pays the MAI management fee and the "wrap fees" the sponsor charges. MAI does not receive a portion of the wrap fees the client pays to the wrap sponsor. Payment of advisory fees to MAI and wrap fees to the sponsor will increase overall costs. Therefore, performance will differ in these "wrap fee" arrangement portfolios compared to other managed portfolios. MAI chooses investments and manages clients' accounts in the wrap fee program like we manage other client accounts using similar strategies. However, because wrap fee programs are often offered by or connected to a broker-dealer, we will use that broker-dealer when placing trades for those accounts. If we used a different broker, that broker might charge the client additional transaction costs, which they already pay under the wrap fee. Our trading practices, described below under Item 12 - Brokerage Practices, may also affect wrap fee clients. Unified Managed Account (“UMA”) Programs MAI provides non-discretionary advice in unified managed account programs ("UMA Programs"). MAI offers model portfolios for a fee to UMA Program sponsors. Those sponsors use MAI's model portfolios as one input in developing their investment recommendations and managing their clients' accounts. MAI's recommendations to UMA Programs sometimes differ from those made to other client accounts. MAI provides the UMA Program sponsor with recommendations on the securities to be purchased, sold, and held in the model portfolio and the percentage of the model portfolio that would be invested in each security. MAI provides this information to the UMA Program sponsor per procedures described in "Trade Rotation" under Item 12 - Brokerage Practices. UMA Program sponsors typically have sole discretion over their clients' accounts. The decision to implement MAI’s recommendations is made by the UMA Program sponsor. Adviser to Mutual Fund MAI is also the investment adviser to the MAI Managed Volatility Fund (MAIPX/DIVPX), an open-end mutual fund part of the Forum Family of Funds. The fund is registered under the Investment Company Act of 1940. MAI is not affiliated with Forum Funds. Adviser to

Private Funds MAI is also an investment adviser to private funds. See Item - 6 Performance Based Fees and Side By Side Management for a list of funds that MAI acts as an investment adviser and charges a performance-based fee and Item 8 - Methods Of Analysis, Investment Strategies and Risk Of Loss. MAI Capital Management, LLC 8 Wealth Management Services In addition to providing investment advice and advisory services, MAI provides to individuals and family offices wealth management services and certain non-advisory services that may be fully integrated as part of a comprehensive offering or, at times, individually. In addition to investment management, these services can include estate and financial planning, advice on tax strategies, use of margin or securities- based loans, insurance, and wealth transfer planning. MAI also prepares United States federal, state, and local tax returns, record keeping, administration of partnership interests and private investments, household management, budgeting and forecasting, and coordination of bill paying and payroll services for household or client corporation employees. We describe fees for wealth management services below under Item 5 - Fees and Compensation. Retirement Account Advice - Individuals MAI provides investment advice to clients regarding their retirement plan account or individual retirement account and are fiduciaries under Title I of the Employee Retirement Income Security Act ("ERISA") and the Internal Revenue Code ("IRC"), as described under Section ii(a)(1) of the U.S. Department of Labor Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”). If MAI recommends that a client roll over their retirement plan assets into an account to be managed by MAI, such a recommendation creates a conflict of interest if MAI will earn a new or increased advisory fee because of the rollover recommendation. The receipt of a new or increased advisory fee resulting from a recommendation creates a conflict of interest for the Firm under ERISA, so MAI operates under PTE 2020-02, which requires the Firm to act in the client's best interest. MAI Retirement - Plan Level MAI Retirement, a division of MAI, provides retirement plan consulting and services to corporate retirement plans. MAI Retirement serves either as the plan's investment adviser pursuant to §3(21) of ERISA (in which case we will recommend investment decisions for approval by the plan's named fiduciaries) or as the plan's investment manager under §3(38) of ERISA (in which case we will manage the plan's investment decisions on a discretionary basis). Regardless of the capacity in which MAI Retirement serves as the adviser, the plan's named fiduciaries or the plan sponsor may impose restrictions on the types of investments held by or offered through the plan. In addition, MAI Retirement does not generally provide advice concerning shares of employee stock held in the plan. Non-Advisory Services MAI provides tax preparation, insurance administration, and family office services, including client accounting, bill paying services, property management, and business consulting services. These services may be integrated with a combination of any other service or available independently, without wealth management services. Insurance Administration Affiliated and unaffiliated insurance brokers provide insurance administration service to MAI clients. MAI Insurance Solutions, LLC (“MAI Insurance”) is a wholly owned subsidiary of MAI that provides Insurance Administration services. Several insurance brokers also sit under Galway Holdings LP - Series 1. These entities are further described in Item 10 - Other Financial Industry Activities and Affiliations. MAI Capital Management, LLC 9 Tailored Services and Client-Imposed Restrictions MAI manages accounts based on the client's circumstances, financial situation, investment objectives, and goals, as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. If the client has a discretionary account, we make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. Our recommendations depend on the current, accurate, and complete information the client provides. The client is responsible for informing MAI of any changes to their investment objectives or restrictions and client information. Clients can request other restrictions on the account, such as when they need to keep a minimum level of cash in the account or want MAI to avoid buying or selling particular securities or security types. MAI reserves the right not to accept and 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. MAI manages pooled investment vehicles according to the fund's investment objectives. Investors in a pooled investment vehicle are unable to place restrictions on the fund. Unmanaged Assets MAI does not maintain any investment monitoring or performance responsibility for unmanaged assets and/or accounts. The client and/or its other investment professionals retain exclusive responsibility for the monitoring and performance of such assets and/or accounts. These assets are included for reporting purposes only. Non-managed assets include securities held in a client’s account that is under management with MAI that were: x delivered into the account by the client; x purchased by the client or purchased by MAI at the request of the client as an accommodation; or x designated by the client to be non-managed securities by written notification. Assets Under Management MAI manages client assets in both discretionary and non-discretionary accounts. As of December 31, 2023, the total amount of assets under our management was $19,251,363,0512 with $17,378,727,222 in discretionary assets and $1,872,635,829 in non-discretionary assets.