Description of Advisory Firm Busey Capital Management, Inc. is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a corporation formed under the laws of the State of Illinois.
• Our firm is ultimately owned and controlled by First Busey Corporation through Busey Bank which is the direct parent company of Busey Capital Management. First Busey Corporation is the direct parent company of Busey Bank. All of our employees are also employees of Busey Bank.
• Busey Investment Services, a division of Busey Bank, and its associates have agreements in place to offer investment services through Raymond James Financial Services, Inc., member FINRA/SIPC, a full-service broker/dealer and Raymond James Financial Services Advisors, Inc., an investment advisor. The Raymond James companies are not Busey affiliated companies. They are run and operated completely separate from First Busey Corporation. The associates of Busey Investment Services that provide investment services do so as registered representatives of Raymond James Financial Services, Inc. and investment advisor representatives of Raymond James Financial Services Advisors, Inc.
• First Busey Corporation is also the parent company of FirsTech, a payment processing company.
• Full details of our affiliates along with a description of their business activities are provided at Item 10 – Other Financial Industry Activities and Affiliations.
• Busey Capital Management has been registered as an investment advisor with the SEC since September 2003. Description of Advisory Services Traditional Investment Advisory Services Our Traditional Investment Advisory Services involve providing clients with continuous and on-going supervision over their accounts we have agreed to manage. This means we will continuously monitor a client’s account and make trades in client accounts when necessary. Through this service, we implement a customized and individualized investment program for clients by applying our investment strategy and philosophy. Busey Capital Management shall actively manage client investment portfolios in accordance with the client's stated investment objectives and risk tolerance. Through our Traditional Investment Advisory Services, we tailor our advisory services to the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. When managing client accounts, we typically manage a client’s account in accordance with one or more investment models that we have developed. When client accounts are managed using models, investment selections are based on the underlying model and we do not develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information about our firm’s models. The assets managed through the Traditional Investment Advisory Services are held in accounts at an unaffiliated third party custodian, currently the Northern Trust Company which will serve as the client’s qualified custodian and maintain physical custody of all client funds and securities (see Item 15 – Custody for more information). You must designate Busey Capital Management as your investment advisor on the accounts you’d like us to manage. Busey Capital Management will be granted limited power-of-attorney on the account to implement trades within the account on a discretionary basis. Please refer to Item 12 for more information regarding the Firm’s brokerage arrangements. Please also refer to Item 16 for an explanation of investment discretion. Clients are always responsible for notifying Busey Capital Management of any changes to their financial situation or investment objectives. At least once per year, we will contact each client for the specific purpose to determine whether the client’s financial situation or investment objectives have changed, or if the client would like to impose and/or modify any reasonable restrictions on the management of their accounts. We are always reasonably available to consult with clients relative to the status of their accounts. A client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the accounts. A separate account is always maintained for each client with the broker-dealer/custodian and the client retains all rights of ownership to their accounts (e. g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). It is important that you understand that Busey Capital Management manages investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed appropriate for your account(s) and other accounts advised by our Firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obliga- tion to disclose the information to any client or use it for any client’s benefit. See Item 5 of this Disclosure Brochure for fee descriptions. Busey’s Signature Solutions Busey Capital Management has developed and offers the Busey Signature Solutions investment management service. This service is provided through an arrangement with Raymond James & Associates utilizing their wrap-fee program called Outside Money Manager Program (“OSM”). Because Signature Solutions is offered through OSM, all accounts must be established through Raymond James Financial Services, Inc., a registered broker/dealer, member SIPC/FINRA, which shall also serve as the client’s qualified custodian (see Item 15 – Custody for more information). Busey Capital Management has no responsibility or control over best price or execution issues due to the fact that the OSM sponsor, Raymond James & Associates, is solely responsible for determining the broker/dealer and trading platform requirements. Through Signature Solutions, Busey Capital Management acts solely as a discretionary asset manager. This means that we will continuously monitor a client’s account and make trades

in client accounts when necessary. However, Busey Capital Management does not have direct client interaction and completely relies on the investment model selection chosen by the client through consultation with client’s primary financial professional. Clients must designate Busey Capital Management as an investment advisor on the Raymond James Financial Services, Inc. accounts they’d like us to manage so that we can implement trades within the accounts on a discretionary basis. Please refer to Item 12 for more information regarding the Firm’s brokerage arrangements. Please also refer to Item 16 for an explanation of investment discretion. All clients will be introduced to Busey’s Signature Solutions by third-party investment advisors. This includes referrals from associates of our affiliate, Busey Investment Services, in their separate capacity as investment advisor representatives of Raymond James Financial Services Advisors, Inc. Prior to recommending Signature Solutions to a client, it is the outside investment advisor representative’s responsibility to interview the client in order to determine the client’s financial position, investment goals and objectives, investment limitations and reasonable restrictions and risk tolerance. The outside investment advisor representative will document the findings of such interview and will provide us with a completed profile questionnaire for the client. The outside investment firm, currently Raymond James, will recommend to clients the strategy that is most appropriately suited to the client’s investment needs in light of the above information gathered. Once the outside investment advisor has selected the strategy most appropriate for the client, the outside investment advisor will provide that information to us along with the client’s financial situation and investment objective information. Client accounts are then managed by our Firm on the basis of the client’s financial situation, investment objectives and stated strategy as provided by the client through the outside investment advisor. The outside investment advisor will maintain direct contact with the client throughout the duration of the agreement. Clients are always responsible for notifying their primary investment advisor representative of any changes to their financial situation or investment objectives. All such changes must be forwarded by the client’s investment advisor representative to Busey Capital Management. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information about our firm’s models. It is important that you understand that Busey Capital Management manages investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed appropriate for your account(s) and other accounts advised by our Firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obliga- tion to disclose the information to any client or use it for any client’s benefit. Although we do not directly solicit clients to this program, Busey Capital Management always reserves the right to have the final authority to accept or reject all client arrangements. The client’s primary investment advisor representative will provide a copy of this Disclosure Brochure, our Investment Advisory Agreement and all other documentation required by Raymond James & Associates as the OSM program sponsor including a copy of the OSM program’s Wrap Fee Program Brochure. Full details of the program are provided in that document. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information about our firm’s models. See Item 5 of this Disclosure Brochure for fee descriptions. Limits Advice to Certain Types of Investments. When managing accounts through our Traditional Investment Advisory Services, we will recommend and invest client assets in a range of investments including:
• No-Load (i.e. no trading fee) and Load-Waived (i.e. trading fee waived) Mutual Fund Shares
• Exchange-listed securities (i.e. stocks)
• Securities traded over-the-counter (i.e. stocks)
• Fixed income securities (i.e. bonds)
• Closed-End Funds and Exchange Traded Funds (ETFs)
• Foreign Issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• United States government securities
• Emerging Market debt securities Investment options for accounts managed through Busey’s Signature Solutions are limited to no-load (i.e. no trading fee) mutual funds, load-waived (i.e. trading fee waived) mutual funds, and ETFs. Busey Capital Management does not provide advice on variable life insurance, variable annuities, options contracts on securities and commodities, futures contracts on tangibles and intangibles, interests in partnerships investing in real estate or oil and gas interests, and hedge funds and other types of private (i.e. non-registered) securities. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information. Participation in Wrap Fee Programs Busey Capital Management offers services through both a wrap-fee program (Busey’s Signature Solutions) and non-wrap fee program (Traditional Advisory Investment Services). A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Whenever a fee charged to a client for services described in this brochure (whether wrap fee or non-wrap fee), Busey Capital Management will receive all or a portion of the fee charged. The management of accounts on a wrap-fee basis differs from the non-wrap accounts in that only mutual funds and ETFs are used in the wrap fee accounts, while the Traditional accounts hold largely individual issues. Exposure to different asset classes is the objective with both types of accounts. Traditional clients will also be in direct contact with BCM associates, while the wrap fee account clients will be in contact with BCM through their advisor at the outside advisory firm. Client Assets Managed by Busey Capital Management The amount of client assets managed by Busey Capital Management totaled $338,778,528 as of December 31, 2023. The entire amount is managed on a discretionary basis.