WTI was founded in 1931 and is 100% owned by Wintrust Bank, N.A., a subsidiary of Wintrust Financial Corporation. WTI offers investment advisory, brokerage and insurance services. WTI is registered as an investment adviser with the SEC, is a member of the Financial Industry Regulatory Authority (“FINRA”) and is licensed to sell insurance in the states where it does so. WTI offers these services to a variety of individuals, trusts, non‐profit organizations, corporations and retirement accounts. The terms “client”, “you”, and “your” are used throughout this Brochure to refer to the person(s) or organization(s) who contract with us for the services described here. Securities transactions for WTI clients are executed by Wells Fargo Clearing Services, LLC (“WFCS”) through a brokerage account opened at WTI. WTI is an introducing broker for your account; WFCS is the clearing broker and custodian for securities transactions executed as part of WTI’s investment advisory services. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Description of Advisory Services WTI provides investment management services to individual and institutional clients on a personalized basis, addressing a particular client’s circumstances through one or more of the following programs: i. Wells Fargo Advisors Investment Advisory Services (collectively “the Programs”) o Personalized Unified Managed Account (“UMA”) ▪ Personalized UMA Multi Strategy ▪ Personalized UMA Single Strategy o Private Advisor Network (“Network”) o Private Investment Management (“PIM”) o Customized Portfolios o Asset Advisor o Custom Choice o FundSource ii. Wintrust Navigator Personal Financial Planning iii. Wintrust Navigator Divorce Planning iv. WTI Institutional Advisory Services i. Wells Fargo Advisors Investment Advisory Services Programs The Programs consist of separately managed account (i.e., “wrap”) programs provided to clients for an inclusive fee, including a mutual fund asset allocation program and discretionary investment advisory services for an advisory fee with the client paying separately for brokerage. WTI offers the Programs through an arrangement with Wells Fargo Advisors. Wells Fargo Advisors is a trade name used by WFCS and Wells Fargo Advisors Financial Network, LLC, separate registered broker- dealers and non-bank affiliates of Wells Fargo & Company. Under the Programs: (1) A WTI investment adviser representative (“Adviser Representative”) considers a client’s pertinent financial and demographic information to develop an investment program that meets the client’s goals and objectives; (2) Excluding the PIM, Asset Advisor, and Custom Choice Programs, the Adviser Representative analyzes client investment objectives, time horizon, liquidity needs, and financial information and recommends an appropriate asset allocation and strategy, which may include use of various sub-managers and investment vehicles such as mutual funds, based on the client’s goals and objectives, investment time horizon, tolerance for risk and other factors deemed pertinent to the client’s individual situation; (3) For all Programs except Asset Advisor and Custom Choice, the sub-manager, Adviser Representative or the investment manager of the investment vehicle, as applicable, provides continuous investment management services on a discretionary basis with respect to the cash and securities in the client’s accounts under the Programs (the “Accounts”); (4) Wells Fargo Advisors, the sub-manager or Adviser Representative, as applicable, through WFCS, effects transactions in securities for the client’s Accounts; and (5) WFCS maintains custody of the client’s assets under the Program. For the services offered under the Programs (with the exception of the Network Program), the client pays an all-inclusive fee out of which WTI pays itself, Wells Fargo Advisors, the sub-manager (as applicable) and WFCS. In the case of Network, Wells Fargo Advisors may be compensated for its services either from a fee, which is payment for both the Network services and execution services, or through brokerage commissions. Network clients pay for the services of the sub-manager separately. Each Program (with the exceptions of Asset Advisor and Custom Choice) is a discretionary asset allocation service. Pursuant to an Investment Management Agreement each client enters into with WTI and Wells Fargo Advisors, in all Programs except for PIM you grant Wells Fargo Advisors discretionary authority to invest and reinvest all assets in your Account, subject to review by your Adviser Representative. In the case of PIM, you grant your Adviser Representative discretionary authority to invest and reinvest all assets in your Account, subject to review by WTI. Such discretion will be exercised in accordance with your goals and objectives, as discussed above. Accordingly, Wells Fargo Advisors or WTI is empowered to buy, sell or to otherwise effect transactions in securities for your Accounts at any time without prior consultation with you, and may delegate such authority to sub- managers. Pursuant to the Investment Management Agreement for the Personalized UMA Program and the FundSource Program, we will inform Wells Fargo Advisors whenever you notify us of any changes to your financial information and investment objectives. When you invest through the PIM, Asset Advisor and Custom Choice Programs, an Adviser Representative acts as portfolio manager for your Account. Asset Advisor and Custom Choice are non- discretionary programs in which your WTI Adviser Representative will make investment recommendations based on your investor profile information and objectives. WTI will not implement such recommendations without your prior approval. The investment management services that WTI and/or Wells Fargo Advisors provide under each Program include:
• Assessment of the client’s investment needs and objectives.
• Investment policy planning.
• Development of an asset allocation strategy designed to meet the client’s objectives.
• Recommendations on suitable style allocations.
• Identification of appropriate sub-managers, investment vehicles, asset classes and/or securities suitable to the client’s goals.
• Evaluation of sub-managers, investment vehicles, asset classes and/or securities meeting style and allocation criteria.
• Engaging selected sub-managers and/or investing in selected investment vehicles, asset classes and/or securities on behalf of the client (for all Programs except Asset Advisor and Custom Choice).
• Ongoing monitoring of performance of individual sub-managers, investment vehicles, asset classes and/or securities.
• Review of the Accounts to ensure adherence to policy guidelines and asset allocation.
• Recommendations for rebalancing of the Accounts, if necessary.
• Reporting of the Accounts’ performance and progress.
• Avoidance of wash sale rule violations.
• Fully integrated back-office support systems, including custody, trade execution and confirmation and statement generation through WFCS. Wells Fargo Advisors may retain sub-managers to manage the Accounts. In some cases, sub-managers construct a model portfolio which is used to invest client assets. WTI will provide you a copy of each applicable sub-manager’s Part 2A of Form ADV or disclosure brochure. Regardless of Account type, your contact source is your Adviser Representative and sub-managers are generally not required to make themselves available to individual clients. The Programs (with the exceptions of Asset Advisor and Custom Choice, which are non-discretionary programs) are intended to comply with Rule 3a-4 under the Investment Company Act of 1940. Rule 3a-4 sets forth certain requirements for programs that offer discretionary portfolio management services to a large number of clients if clients with similar investment objectives receive the same investment advice or hold the same or substantially the same securities in their accounts. Each Account is managed on the basis of the client’s individual financial situation. Each client has the opportunity to select the Account’s investment objective and impose reasonable restrictions on the management of the assets in the Account. In addition, WTI contacts clients annually to confirm the accuracy of their investor profile information. Additional information regarding the Wells Fargo Advisors Wrap Programs can be found in the Brochure Appendix. ii. Wintrust Navigator Personal Financial Planning Our financial planning services typically involve a variety of advisory services aimed at managing a client’s financial resources based upon an analysis of their individual needs. Financial planning services include, but are not limited to, cash flow management, retirement planning, tax planning, risk management, education funding, estate planning, and more. Our financial planning services can range from broad, comprehensive financial planning consisting of three or more of these services that is based on an ongoing relationship, to hourly consulting for a specific project. Comprehensive financial planning involves working one-on-one with us over an extended period of time. The comprehensive financial planning process focuses on your goals and values around money. During the process, we require you to provide an adequate level of information and supporting documentation in order for us to provide advisory services. Once your information is reviewed and analyzed, we create a broad based or modular plan and present you a summary of our recommendations. You are under no obligation to act on our financial planning recommendations, but the success of your plan is contingent on your engagement in the process and following through on the recommendations. If a comprehensive financial planning approach is not suitable or does not meet your needs, a limited scope engagement is available. Our hourly rate will apply for any limited scope engagement. For a limited scope engagement, the scope of services will be agreed to in advance and an approximate range of hours will be provided. Financial planning services include, but are not limited to:  Cash Flow and Debt Management (2-10 hours): We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts.  College Savings (2-10 hours): Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if applicable, we may review your financial picture as it relates to the best way to contribute to grandchildren.  Employee Benefits Optimization (2-10 hours): We may provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. This will include a review of the benefits program, identifying savings maximization using the company match, and tracking of additional benefits such as stock options and restricted stock awards.  Business Owner (5-30 hours): If you are a business owner, we may consider and or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. In addition, we will make recommendations

regarding succession planning, disability, and retirement plans for employees.  Estate Planning (5-30 hours): This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trust. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time to time, we will participate in meetings or phone calls between you and your attorney with your approval or request.  Financial Goals (5-25 hours): We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal both in the short term and the long term.  Risk Management (2-10 hours): A risk management review may include an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self‐insuring”).  Investment Analysis (5 – 25 hours): This may involve developing an asset allocation strategy to meet clients’ financial goals and risk- tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure.  Retirement Planning (5–30 hours): Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years.  Tax Planning Strategies (5–30 hours): Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Wells Fargo Advisors does not sponsor or advise WTI in connection with its financial planning services. Implementation If you retain us to implement a financial plan, our advisory personnel may also design and construct an investment portfolio that is consistent with your financial objectives. As part of this service, your Adviser Representative will recommend specific investments to be included in your portfolio. While determined in large measure by your individual goals/objectives, our portfolio design philosophy is a process of strategic asset allocation among three asset classes: fixed income, equities and alternative investments. As part of a financial plan, an Adviser Representative may recommend changes to a client’s health, life, disability or long-term care insurance coverage. Clients may elect to implement the insurance advice by purchasing a policy through one of our representatives in their capacity as a licensed insurance agent of various insurance agencies or companies. Brokerage execution will be conducted through WFCS with WTI as introducing broker. Brokerage commissions may be assessed. Transactional fees are in addition to financial planning fees. See Items 11 and 12 below for more information on our conflicts of interest and brokerage practices. iii. Wintrust Navigator Divorce Planning Our Certified Divorce Financial Analyst® professionals provide divorce planning services that typically involve a variety of investment advisory services aimed at managing a client’s financial resources based upon an analysis of their individual needs. Comprehensive divorce planning involves working one-on-one with us over an extended period of time. The comprehensive planning process focuses on your divorce settlement or different divorce settlement options. During the process, we require you to provide an adequate level of information and supporting documentation in order for us to provide advisory services. Once your information is reviewed and analyzed, we create a broad based or modular plan and present you a summary of our recommendations. You are under no obligation to act on our divorce planning recommendations, but the success of your plan is contingent on your engagement in the process and following through on the recommendations. If our comprehensive divorce planning approach exceeds your needs, a limited scope engagement is available. Our hourly rate will apply for any limited scope engagement. For a limited scope engagement, the scope of services will be agreed to in advance and an approximate range of hours will be provided. Divorce planning services include, but are not limited to:  Financial Analysis in Divorce (2-10 hours): We will conduct a review of the marriage settlement or proposed settlements. Specifically, we will analyze how isolated decisions can affect the big picture. Different divisions of property (equitable or not), inflation, investment returns, debt and the long-term impact of the financial settlement. As such, each input must be understood and analyzed as each input can significantly impact the settlement.  Marital and Separate Property (2-10 hours): Identify and analyze marital and separate property. We will value each asset and understand and measure the risks and limitations of division. Moreover, we’ll determine an optimal allocation of such assets to each party.  Division of Retirement Plans and Potential Tax Consequences (2-10 hours): We will discover the individual retirement plans used and consider how such plans could be divided either by plan, by the total retirement plan assets, and/or as part of the aggregate split of assets. Specifically, we’ll correctly allocate retirement dollar against non-retirement dollars to achieve a desired outcome; and we’ll contemplate the appropriateness of a Qualified Domestic Relations Order. In addition, we’ll evaluate and price any defined benefit pension plan and model efficient distribution strategies from retirement plans in a tax efficient manner. Finally, we’ll contemplate protecting the survivor benefits for the non-employee spouse.  Spousal and Child Support (2-10 hours): Analyze the structure of spousal and child support payments and understand the tax implications of each for both pre-2019 divorces and after. We’ll consider how the use of life insurance might serve to protect support payments and the proper ownership of said insurance.  IRS Sections Specific to Divorce and Filing Status (2-10 hours): We will consider tax implications and transaction costs of a settlement offer for a myriad of investment options and the effect of tax deferral when dividing assets or receiving spousal support.  Valuing and Selling the Marital Home (2-10 hours): Determine if retaining the marital home is feasible after settlement. Consider the cost basis of the home and the special tax ramifications of selling it for each party. Wells Fargo Advisors does not sponsor or advise WTI in connection with its divorce planning services. Implementation If you retain us to implement a divorce plan, our advisory personnel may also design and construct an investment portfolio that is consistent with your financial objectives. As part of this service, your Adviser Representative will recommend specific investments to be included in your portfolio. While determined in large measure by your individual goals/objectives, our portfolio design philosophy is a process of strategic asset allocation among three asset classes: fixed income, equities and alternative investments. As part of a divorce plan, an Adviser Representative may recommend changes to a client’s health, life, disability or long-term care insurance coverage. Clients may elect to implement the insurance advice by purchasing a policy through one of our representatives in their capacity as a licensed insurance agent of various insurance agencies or companies. Brokerage execution will be conducted through WFCS with WTI as introducing broker. Brokerage commissions may be assessed. Transactional fees are in addition to financial planning fees. See Items 11 and 12 below for more information on our conflicts of interest and brokerage practices. iv. WTI Institutional Advisory Services WTI provides discretionary investment advisory services solely to Wintrust Financial Corporation, using third party custodians for which the client may also pay brokerage commissions. With this service, (1) the Portfolio Manager completes pertinent financial and demographic information regarding the client in order to develop an investment program that meets the client’s goals and objectives; (2) the Portfolio Manager analyzes such information and recommends an appropriate asset allocation and strategy based on the client’s goals and objectives, investment time horizon, tolerance for risk and other factors deemed pertinent to the client’s individual situation; (3) the Portfolio Manager provides continuous investment management services on a discretionary basis with respect to the cash and securities in the client’s accounts (“Account”) under the Program. Pursuant to an Investment Management Agreement between WTI and the client, the client grants WTI discretionary authority to invest and reinvest all assets in the client’s Account. Such discretion will be exercised in accordance with the client’s goals and objectives, as discussed above. The investment advisory services provided by WTI under this program include:
• Assessment of the client investment needs and objectives.
• Investment policy planning.
• Development of an asset allocation strategy designed to meet the client objectives.
• Recommendations on suitable style allocations.
• Identification of appropriate investment vehicles, asset classes and/or securities suitable to the client goals.
• Evaluation of investment vehicles, asset classes and/or securities meeting style and allocation criteria.
• Investing in selected investment vehicles, asset classes and/or securities on behalf of the client.
• Ongoing monitoring of performance of investment vehicles, asset classes and/or securities.
• Review of the Accounts to ensure adherence to policy guidelines and asset allocation.
• Recommendations for rebalancing of the Accounts, if necessary.
• Reporting of the Accounts’ performance and progress.
• Avoidance of wash sale rule violations. Wells Fargo Advisors does not sponsor or advise WTI under this program. Assets Under Management Total regulatory assets calculated as of 12/31/2023: Discretionary: $ 9,283,903,368 Non-Discretionary: $ 5,133,924,358