A. myCIO Wealth Partners, LLC (“myCIO”, the “Registrant”, the “Firm”) was organized as a limited liability company on March 23, 2005 in the Commonwealth of Pennsylvania and, on October 1, 2015, converted to a Delaware limited liability company. The Registrant became registered as an Investment Adviser Firm in April 2005. The Registrant’s advisory business is overseen by Partners James Joseph Biles, David Edmund Lees and Paul Joseph Bracaglia. In October 2015, Affiliated Managers Group, Inc. (“AMG”) acquired an equity interest in the Registrant. The Registrant’s Partners hold the remaining equity interests in the Firm. AMG, a publicly traded asset management company (NYSE: AMG), also holds equity interests in certain other investment advisers (“AMG Affiliates”). Further information on AMG and the AMG Affiliates is provided in Item 10. B. As discussed below, the Registrant offers to its clients (individuals, business entities, trusts, estates, charitable organizations, pension and profit-sharing plans, etc.) investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES The client can determine to engage the Registrant to provide discretionary and/or non- discretionary investment advisory services on a fee-only basis. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management. The Registrant provides investment advisory services specific to the needs of each client. Before providing investment advisory services, the Registrant will ascertain each client’s investment objectives. Thereafter, the Registrant will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, the Registrant provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may rebalance or recommend rebalancing the account based on such reviews. PRIVATE INVESTMENT FUNDS Affiliated Private Funds. The Registrant is affiliated with several private investment funds: REF Partners, LP, RUS Partners, LP, , BRP II, LP, RSF Partners, LP, RSPAC Partners, LP, and RSDF Partners, LP (collectively, the “affiliated funds”). Condensed descriptions of each affiliated fund are set forth below. The Registrant, on a non- discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to the affiliated funds. The terms and conditions for participation in the affiliated funds, including management and incentive fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents. Registrant’s clients are under no obligation to consider or make an investment in the affiliated funds. Risk Factors. Private investment funds, such as the affiliated funds, generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each qualified client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Conflicts of Interest. To the extent that the Registrant manages any client account as an investment adviser and the client is also an investor in one or more of the affiliated funds, the Registrant will be entitled to an investment advisory fee as described in either the Investment Advisory Agreement and/or Financial Planning Agreement, in addition to an administrative fee received by the Registrant for services provided to one or more of the affiliated funds. The Registrant’s Chief Compliance Officer, James J. Biles, remains available to address any questions regarding this conflict of interest. Valuation. In the event that the Registrant references private investment funds owned by the client on any supplemental account reports prepared by the Registrant, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. If the fund sponsor does not provide a post- purchase valuation, then the valuation shall reflect the initial purchase price (and/or a value as of a previous date) or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects the initial purchase price (and/or a value as of a previous date), then the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. The client’s advisory fee shall be based upon such reflected fund value(s). REF Partners, LP The Registrant’s related party, myCIO Hedge Fund Advisors, LLC, serves as the General Partner for REF Partners, LP, a Delaware limited partnership (referred to as the “REF Fund”), which is an affiliated private investment limited partnership offered in accordance with Regulation D under SEC regulations. To the extent that certain of the Registrant’s individual advisory clients qualify, and determine that an investment is appropriate given their investment objective(s) and financial situation, they may be eligible to participate as limited partners in the REF Fund. The REF Fund will then allocate investment assets within the RIEF Strategic Partners Fund LLC, an unaffiliated investment vehicle. Investment in the REF Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the REF Fund, including the administrative fee to be paid to the Registrant, suitability, investment strategy, risk factors, and potential conflicts of interest, are set forth in the Private Offering Memorandum, Limited Partnership Agreement, and Subscription Agreement, which each subscriber is required to receive and/or execute prior to being accepted as a Limited Partner of the REF Fund. In such capacity (as a related party to the general partner of the REF Fund), the Registrant receives a fee from REF Partners in consideration of the Registrant managing REF Partners’ operations. The annual administrative fee payable to the Registrant (through its affiliate) under the partnership agreement of REF Partners equals 0.50% (50 basis points) of the aggregate Capital Account balances of all Limited Partners (including the Registrant’s clients) of REF Partners. Such annual administrative fee is in addition to fees charged by RIEF Strategic Partners Fund LLC. REF Partners (and thus Limited Partners of REF Partners, who may be the Registrant’s clients) is responsible for fund fees and expenses (such fees and expenses include organizational expenses of REF Partners, custodial fees, interest and other lenders’ charges (if any), taxes (other than income taxes, which will be the responsibility of the Limited Partners), brokerage commissions paid in the course of the purchase or sale of securities, legal, accounting, auditing and tax return preparation fee and expenses, auditing, tax return preparation fees, and all other expert and consulting fees and expenses arising in connection with REF Partners’ business). The General Partner, myCIO Hedge Fund Advisors, LLC, which is fully and solely owned by the Registrant, has an ownership interest in the REF Fund. RUS Partners, LP The Registrant’s related party, myCIO Hedge Fund Advisors, LLC, serves as the General Partner for RUS Partners, LP, a Delaware limited partnership (referred to as the “RUS Fund”), which is an affiliated private investment limited partnership offered in accordance with Regulation D under SEC regulations. To the extent that certain of the Registrant’s individual advisory clients qualify, and determine that an investment is appropriate given their investment objective(s) and financial situation, they may be eligible to participate as limited partners in the RUS Fund. The RUS Fund will then allocate investment assets within the Radcliffe Domestic Ultra Short Duration Fund, L.P., an unaffiliated investment vehicle. Investment in the RUS Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the RUS Fund, including the administrative fee to be paid to the Registrant, suitability, investment strategy, risk factors, and potential conflicts of interest, are set forth in the Private Offering Memorandum, Limited Partnership Agreement, and Subscription Agreement, which each subscriber is required to receive and/or execute prior to being accepted as a Limited Partner of the RUS Fund. In such capacity (as a related party to the general partner of the RUS Fund), the Registrant receives a fee from the RUS Fund in consideration of the Registrant managing the RUS Fund’s operations. The annual administrative fee payable to the Registrant (through its affiliate) under the partnership agreement of the RUS Fund equals 0.25% (25 basis points) of the aggregate Capital Account balances of all limited partners (including the Registrant’s clients) of the RUS Fund. Such annual administrative fee is in addition to fees charged by Radcliffe Domestic Ultra Short Duration Fund, L.P. The RUS Fund (and thus limited partners of the RUS Fund, who may be the Registrant’s clients) is responsible for RUS Fund fees and expenses (such fees and expenses include organizational expenses of the RUS Fund, custodial fees, interest and other lenders’ charges (if any), taxes (other than income taxes, which will be the responsibility of the limited partners), brokerage commissions paid in the course of the purchase or sale of securities, legal, accounting, auditing and tax return preparation fee and expenses, auditing, tax return preparation fees, and all other expert and consulting fees and expenses arising in connection with Fund’s business). The General Partner, myCIO Hedge Fund Advisors, LLC, which is fully and solely owned by the Registrant, has an ownership interest in the RUS Fund. BRP II, LP The Registrant’s related party, myCIO Hedge Fund Advisors, LLC, serves as the General Partner for BRP II, LP, a Delaware limited partnership (referred to as the “BRP Fund”), which is an affiliated private investment limited partnership offered in accordance with Regulation D under SEC regulations. To the extent that certain of the Registrant’s individual advisory clients qualify, and determine that an investment is appropriate given their investment objective(s) and financial situation, they may be eligible to participate as limited partners in the BRP Fund. The BRP Fund will then allocate investment assets within the Bay II Resource Partners, L.P. Fund, an unaffiliated investment vehicle. Investment in the BRP Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the BRP Fund, including the administrative fee to be paid to the general partner, suitability, investment strategy, risk factors, and potential conflicts of interest, are set forth in the Private Offering Memorandum, Limited Partnership Agreement, and Subscription Agreement, which each subscriber is required to receive and/or execute prior to being accepted as a Limited Partner of the BRP Fund. In such capacity (as a related party to the General Partner of the BRP Fund), the Registrant receives a fee from the BRP Fund in consideration of the Registrant managing the BRP Fund’s operations. The annual administrative fee payable to the Registrant (through its affiliate) under the partnership agreement of the BRP Fund equals 0.50% (50 basis points) of the aggregate capital account balances of all Limited Partners (including the Registrant’s clients) of the BRP Fund. Such annual administrative fee is in addition to fees charged by Bay II Resource Partners, L.P. Fund. The BRP Fund (and thus Limited Partners of the BRP Fund, who may be the Registrant’s clients) is responsible for BRP Fund fees and expenses (such fees and expenses include organizational expenses of the BRP Fund, custodial fees, interest and other lenders’ charges (if any), taxes (other than income taxes, which will be the responsibility of the Limited Partners), brokerage commissions paid in the course of the purchase or sale of securities, legal, accounting, auditing and tax return preparation fee and expenses, auditing, tax return preparation fees, and all other expert and consulting fees and expenses arising in connection with BRP Fund’s business). The General Partner, myCIO Hedge Fund Advisors, LLC, which is fully and solely owned by the Registrant, has an ownership interest in the BRP Fund. RSF Partners, LP The Registrant’s related party, myCIO Hedge Fund Advisors, LLC, serves as the General Partner for RSF Partners, LP, a Delaware limited partnership (referred to as the “RSF Fund”), which is an affiliated private investment limited partnership offered in accordance with Regulation D under SEC regulations. To the extent that certain of the Registrant’s individual advisory clients qualify, and determine that an investment is appropriate given their investment objective(s) and financial situation, they may be eligible to participate as limited partners in the RSF Fund. The RSF Fund will then allocate investment assets within the Radcliffe Domestic Ultra Short Duration Select Fund, L.P., an unaffiliated investment vehicle. Investment in the RSF Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the RSF Fund, including the administrative fee to be paid to the Registrant, suitability, investment strategy, risk factors, and potential conflicts of interest, are set forth in the Private Offering Memorandum, Limited Partnership Agreement, and Subscription Agreement, which each subscriber is required to receive and/or execute prior to being accepted as a Limited Partner of the RSF Fund. In such capacity (as a related party to the General Partner of the RSF Fund), the Registrant receives a fee from the RSF Fund in consideration of the Registrant managing the RSF Fund’s operations. The annual administrative fee payable to the Registrant (through its affiliate) under the partnership agreement of the RSF Fund equals 0.20% (20 basis points) of the aggregate capital account balances of all Limited Partners (including the Registrant’s clients) of the RSF Fund. Such annual administrative fee is in addition to fees charged by Radcliffe Domestic Ultra Short Duration Select Fund, L.P. The RSF Fund (and thus Limited Partners of the RSF Fund, who may be the Registrant’s clients) is responsible for RSF Fund fees and expenses (such fees and expenses include organizational expenses of the RSF Fund, custodial fees, interest and other lenders’ charges (if any), taxes (other than income taxes, which will be the responsibility of the Limited Partners), brokerage commissions paid in the course of the purchase or sale of securities, legal, accounting, auditing and tax return preparation fee and expenses, auditing, tax return preparation fees, and all other expert and consulting fees and expenses arising in connection with RSF Fund’s business). The General Partner, myCIO Hedge Fund Advisors, LLC, which is fully and solely owned by the Registrant, has an ownership interest in the RSF Fund. RSPAC Partners, LP The Registrant’s related party, myCIO Hedge Fund Advisors, LLC, serves as the General Partner for RSPAC Partners, LP, a Delaware limited partnership (referred to as the “RSPAC Fund”), which is an affiliated private investment limited partnership offered in accordance with Regulation D under SEC regulations. To the extent that certain of the Registrant’s individual advisory clients qualify, and determine that an investment is appropriate given their investment objective(s) and financial situation, they may be eligible to participate as limited partners in the RSPAC Fund. The RSPAC Fund will then allocate investment assets within the Radcliffe Domestic SPAC Fund, L.P., an unaffiliated investment vehicle. Investment in the RSPAC Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the RSPAC Fund, including the administrative fee to be paid to the Registrant, suitability, investment strategy, risk factors, and potential conflicts of interest, are set forth in the Private Offering Memorandum, Limited Partnership Agreement, and Subscription Agreement, which each subscriber is required to receive and/or execute prior to being accepted as a Limited Partner of the RSPAC Fund. In such capacity (as a related party to the general partner of the RSPAC Fund), the Registrant receives a fee from the RSPAC Fund in consideration of the Registrant managing the RSPAC Fund’s operations. The annual administrative fee payable to the Registrant (through its affiliate) under the partnership agreement of the RSPAC Fund equals 0.35% (35 basis points) of the aggregate Capital Account balances of all Limited Partners (including the Registrant’s clients) of the RSPAC Fund. Such annual administrative fee is in addition to fees charged by Radcliffe Domestic SPAC Fund, L.P. The RSPAC Fund (and thus Limited Partners of the RSPAC Fund, who may be the Registrant’s clients) is responsible for RSPAC Fund fees and expenses (such fees and expenses include organizational expenses of the RSPAC Fund, custodial fees, interest and other lenders’ charges (if any), taxes (other than income taxes, which will be the responsibility of the Limited Partners), brokerage commissions paid in the course of the purchase or sale of securities, legal, accounting, auditing and tax return preparation fee and expenses, auditing, tax return preparation fees, and all other expert and consulting fees and expenses arising in connection with RSPAC Fund’s business). The General Partner, myCIO Hedge Fund Advisors, LLC, which

is fully and solely owned by the Registrant, has an ownership interest in the RSPAC Fund. RSDF Partners, LP The Registrant’s related party, myCIO Hedge Fund Advisors, LLC, serves as the General Partner for RSDF Partners, LP, a Delaware limited partnership (referred to as the “RSDF Fund”), which is an affiliated private investment limited partnership offered in accordance with Regulation D under SEC regulations. To the extent that certain of the Registrant’s individual advisory clients qualify, and determine that an investment is appropriate given their investment objective(s) and financial situation, they may be eligible to participate as limited partners in the RSDF Fund. The RSDF Fund will then allocate investment assets within the Radcliffe Short Duration Fund, L.P., an unaffiliated investment vehicle. Investment in the RSDF Fund involves a significant degree of risk. All relevant information, terms and conditions relative to the RSDF Fund, including the administrative fee to be paid to the Registrant, suitability, investment strategy, risk factors, and potential conflicts of interest, are set forth in the Private Offering Memorandum, Limited Partnership Agreement, and Subscription Agreement, which each subscriber is required to receive and/or execute prior to being accepted as a Limited Partner of the RSDF Fund. In such capacity (as a related party to the General Partner of the RSDF Fund), the Registrant receives a fee from the RSDF Fund in consideration of the Registrant managing the RSDF Fund’s operations. The annual administrative fee payable to the Registrant (through its affiliate) under the partnership agreement of the RSDF Fund equals 0.275% (27.5 basis points) of the aggregate capital account balances of all Limited Partners (including the Registrant’s clients) of the RSDF Fund. Such annual administrative fee is in addition to fees charged by Radcliffe Short Duration Fund, L.P. The RSDF Fund (and thus Limited Partners of the RSDF Fund, who may be the Registrant’s clients) is responsible for RSDF Fund fees and expenses (such fees and expenses include organizational expenses of the RSDF Fund, custodial fees, interest and other lenders’ charges (if any), taxes (other than income taxes, which will be the responsibility of the Limited Partners), brokerage commissions paid in the course of the purchase or sale of securities, legal, accounting, auditing and tax return preparation fee and expenses, auditing, tax return preparation fees, and all other expert and consulting fees and expenses arising in connection with RSDF Fund’s business). The General Partner, myCIO Hedge Fund Advisors, LLC, which is fully and solely owned by the Registrant, has an ownership interest in the RSDF Fund. Unaffiliated Private Investment Funds. The Registrant may also provide investment advice regarding unaffiliated private investment funds. The Registrant, on a non- discretionary basis, may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. The Registrant’s role relative to the unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Registrant calculating its investment advisory fee. The Registrant’s clients are under no obligation to consider or make an investment in an unaffiliated private investment fund(s). In certain cases, unaffiliated private investment funds recommended by the Registrant may include funds sponsored or advised by AMG Affiliates. None of AMG or any AMG Affiliate has any involvement or influence in the Registrant’s selection of unaffiliated private investment funds. As such, AMG’s ownership interest in the Registrant does not, in the Registrant’s view, present any potential conflict of interest for the Registrant with respect to our clients. The Registrant’s Chief Compliance Officer, James J. Biles, remains available to address any questions concerning the Registrant’s selection of unaffiliated private investment funds. Risk Factors: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation. In the event that the Registrant references private investment funds owned by the client on any supplemental account reports prepared by the Registrant, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. If the fund sponsor does not provide a post- purchase valuation, then the valuation shall reflect the initial purchase price (and/or a value as of a previous date) or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects the initial purchase price (and/or a value as of a previous date), then the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. The client’s advisory fee shall be based upon such reflected fund value(s). FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent requested by a client, the Registrant may determine to provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) at the request of the client on a stand-alone separate fee basis. The Registrant’s planning and consulting fees are negotiable depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with the Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to the Registrant commencing services. If requested by the client, the Registrant may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. RETIREMENT PLAN CONSULTING SERVICES The client can engage the Registrant to provide retirement plan consulting services on a non-discretionary fee-only basis. Under such an engagement, the Registrant assists sponsors of self-directed retirement plans and defined benefit plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. To the extent requested by the plan sponsor, the Registrant may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between the Registrant and the plan sponsor. TAX PREPARATION SERVICES To the extent requested by the client, the Registrant may provide tax preparation services on a stand-alone, separate fee basis. MISCELLANEOUS Limitations of Non-Investment Consulting/Implementation Services. To the extent requested by the client, the Registrant may provide consulting services regarding non- investment related matters, such as estate planning, tax planning, insurance, etc. Neither the Registrant, nor any of its representatives, serves as an attorney or licensed insurance agent, and no portion of the Registrant’s services should be construed as legal services or insurance implementation services. Accordingly, the Registrant does not prepare estate planning documents or sell insurance products. To the extent requested by a client, the Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. Non-Discretionary Service Limitations. Clients that engage Registrant on a non- discretionary investment advisory basis must be willing to accept that Registrant cannot affect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that Registrant would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, the Registrant will be unable to affect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Sub-Advisory Arrangements. The Registrant may engage sub-advisors for the purpose of assisting the Registrant with the management of its client accounts. The sub-advisor(s) shall have discretionary authority for the day-to-day management of the assets that are allocated to it by the Registrant. The sub-advisor shall continue in such capacity until such arrangement is terminated or modified by the Registrant. The Registrant shall pay a portion of the investment advisory fee received for these allocated assets to the sub- advisor for its sub-advisory services. In certain cases, the sub-adviser engaged by the Registrant may include AMG Affiliates. Neither AMG nor any AMG Affiliate has any involvement or influence in the Registrant’s selection of sub-advisors. As such, AMG’s ownership interest in the Registrant does not, in the Registrant’s view, present any potential conflict of interest for the Registrant with respect to our clients. The Registrant’s Chief Compliance Officer, James J. Biles, remains available to address any questions concerning the Registrant’s sub-advisory arrangements. Independent Managers. The Registrant may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets according to the terms and conditions of a separate agreement executed between the client and the Independent Manager. The Registrant shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which the Registrant shall consider in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. In certain cases, Independent Managers selected by the Registrant may include AMG Affiliates. Neither AMG nor any AMG Affiliate has any involvement or influence in the Registrant’s selection of Independent Managers. As such, AMG’s ownership interest in the Registrant does not, in the Registrant’s view, present any potential conflict of interest for the Registrant with respect to our clients. The Registrant’s Chief Compliance Officer, James J. Biles, remains available to address any questions concerning the Registrant’s selection of Independent Managers. Client Obligations. In performing its services, the Registrant shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising the Registrant’s previous recommendations and/or services. Use of REITs. The Registrant may allocate or recommend the allocation of client investment assets to non-traded / non-public Real Estate Investment Trusts (“REITs”), which are subject to risks generally associated with investing in real estate, such as: possible declines in the value of real estate; adverse general and local economic conditions; possible lack of availability of mortgage funds; changes in interest rates; and environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and potential losses of self-liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility. Use of Mutual Funds. While the Registrant may recommend allocating investment assets to mutual funds that are not available directly to the public, the Registrant may also recommend that clients allocate investment assets to publicly-available mutual funds that the client could obtain without engaging the Registrant as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly-available mutual funds without engaging the Registrant as an investment adviser, the client or prospective client would not receive the benefit of the Registrant’s initial and ongoing investment advisory services. Other mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”), are generally only available through registered investment advisers. The Registrant may allocate client investment assets to DFA mutual funds. Therefore, upon the termination of the Registrant’s services to a client, restrictions regarding transferability and/or additional purchases of, or reallocation among DFA funds will apply. Retirement Plan Rollovers-No Obligation/Conflict of Interest. A client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in his/her former employer’s plan, if permitted, (ii) roll over the assets to his/her new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). The Registrant may recommend an investor roll over plan assets to an IRA managed by the Registrant. As a result, the Registrant and its representatives may earn an asset-based fee (see Note below). In contrast, a recommendation that a client or prospective client leave his or her plan assets with his/her former employer or roll the assets to a plan sponsored by a new employer may or may not result in compensation to the Registrant, depending on whether the client has engaged the Registrant to monitor and/or manage the account while maintained at his/her employer. The Registrant has an economic incentive to encourage a client to roll plan assets into an IRA that the Registrant will manage or to engage the Registrant to monitor and/or manage the account while maintained at the client’s employer. There are various factors that the Registrant may consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus the Registrant’s, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. No client is under any obligation to roll over plan assets to an IRA managed by the Registrant or to engage the Registrant to monitor and/or manage the account while maintained at the client’s employer. Please Note: If the Registrant’s engagement will include the management of the client’s retirement account per the same fee schedule set forth in Item 5 below, regardless of custodian or the client’s decision to process a rollover, the above economic incentive to recommend a rollover is generally not present. The Registrant’s Chief Compliance Officer, James J. Biles, remains available to address any questions that a client or prospective client may have regarding its prospective engagement and the corresponding conflict of interest presented by such engagement. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. The Registrant does not provide investment advisory services to wrap fee programs. E. As of December 31, 2023, the Registrant had $507,502,757 in assets under management on a discretionary basis, and $12,460,640,763 in assets under management on a non-discretionary basis.