The Firm’s History and its Owners Keel Point, LLC was founded in 1998 and BlueCreek Investment Partners, LLC was founded in 2003. In January 2015, Keel Point, LLC and BlueCreek Investment Partners, LLC merged and with clients’ consent, assets managed by BlueCreek Investment Partners, LLC were assigned to Keel Point, LLC (the “Firm” and sometimes referred to herein as “our” or “us” or “we” as appropriate). The Firm’s home office is located in Huntsville, Alabama, with branch offices in Birmingham, Alabama; Leawood, Kansas; Brentwood, Tennessee; Chattanooga, Tennessee; Greenville, North Carolina; and Vienna, Virginia. The Firm and its affiliates, Keel Point Capital, LLC (“KPC”), a broker-dealer registered with the SEC, Keel Point Insurance Advisors, LLC (“KPIA”), a licensed insurance agency, and Keel Point Personal Money Management, LLC (“KPPMM”), an investment adviser registered with the Alabama Securities Commission that primarily provides non-discretionary daily money management services for individuals, are wholly owned by Keel Point Partners LLC (“KPP”). KPP is owned by certain client- investors and members of our management team. In addition, the Firm is the sole member and sole manager of KP Convexity GP, LLC (“KP Convexity”), a special purpose vehicle whose activities are limited to serving as a special limited partner of certain private funds in which the Firm serves as a sub- adviser. The Firm, in its capacity as the manager of KP Convexity, has full discretion to manage and control KP Convexity, including the sole responsibility for performing the day-to-day management and supervision of the performance of KP Convexity’s operations through a unified compliance program administered by the Firm’s Chief Compliance Officer. In such capacity, the Firm provides KP Convexity with certain supervisory support services (the “Supervisory Support Services”), including (i) providing KP Convexity with staffing, services and related resources such as compliance, accounting and clerical staff as necessary to enable KP Convexity to comply with the Investment Advisers Act of 1940 (the “Advisers Act”); (ii) supervising and controlling the performance of any investment advisory activities performed by KP Convexity; (iii) maintaining the required books and records related to KP Convexity’s investment advisory activities; and (iv) maintaining appropriate securities licensing and performing other compliance and support services as necessary to ensure compliance with the Advisers Act. In return, KP Convexity and its employees are subject to: (i) the Firm’s supervision and control, including complying with the Firm’s code of ethics and written compliance policies and procedures; (ii) the Advisers Act and related rules; (iii) examination by any applicable governmental authorities, including the SEC; and (iv) the oversight of the Firm’s Chief Compliance Officer. A detailed

description of the Firm’s ownership structure is in Item 10: Other Financial Industry Activities and Affiliations. The Firm currently offers discretionary and non-discretionary investment advisory services, including providing financial planning, asset allocation, and portfolio construction recommendations, as well as managing client accounts across a range of asset classes and investments. At our core, we focus on delivering investment advisory services across a broad spectrum of clients, including individual wealth management and private client services, family office services, institutional services, including the construction and management of investment portfolios, and corporate financial services, including employee benefit and retirement plan services. However, we do not offer tax, accounting, regulatory, or legal advisory services. You should seek outside counsel for these services. The Advisory Services We Offer The Firm offers clients a seamless combination of an open architecture investment platform with KPC, its broker-dealer affiliate, for a fully integrated wealth management offering. The Firm employs an open architecture investment platform to fulfill each client’s investment strategy, which provides investment exposure to a full range of asset classes via mutual funds, exchange traded funds, options, structured financial products and separate accounts managed by KPC or unaffiliated third parties. We also recommend investments in privately offered pooled investment vehicles, such as hedge funds, private equity funds or other similar vehicles for clients who are qualified to invest in those funds and for whom those investments are otherwise deemed to be appropriate. Currently, the Firm offers its individual, institutional and corporate clients discretionary and non- discretionary investment advisory services primarily through one or more of the following service platforms:  Keel Point Private Client Services. Investment advisory services for individuals and families;  Keel Point Horizon Services. Family office services for ultra-high net worth families;  Keel Point Corporate Services. Group retirement and benefits solutions for businesses; and  Keel Point Asset Management. Outsourced chief investment officer and investment consulting services for institutions, foundations, endowments and third-party investment advisers. For each service platform, we gather information regarding client goals, investment objectives, and risk tolerance by conducting extensive interviews with our clients to determine each client’s risk profile and obtain the necessary information to enable us to construct a tailored investment program for each client. As part of our investment advisory services, we monitor the performance of client portfolios against certain agreed upon benchmarks, assess the performance of any of our Sub-Advisers (as defined in