TwinFocus is a family office and investment advisory boutique serving the needs of high‐ and ultra‐high net worth individuals, families, and their related family entities. TwinFocus’ founders and principals, Paul Karger and Wesley Karger, sought to establish a unique global financial services firm where their philosophy and capabilities could work to best deliver success to a select group of advisory clients (“Client”). As such, the firm is driven by the principle of providing comprehensive, high quality, objective investment advice, free from the conflicts typically inherent in many financial advisory arrangements. TwinFocus has been in business as a registered investment adviser since May 23, 2006. As of December 31, 2023, TwinFocus had $3,585,714,961 of regulatory assets under management1, of which $2,376,203,032 is managed on a discretionary basis and $1,209,511,930 is managed on a non‐ discretionary basis. As of the same date, TwinFocus had $7,853,406,545 of total assets under advisement.2 In addition to assets under management, the firm’s assets under advisement includes private investments in direct opportunities, private equity, venture capital, real estate, and hedge funds, where TwinFocus does not typically provide continuous and regular supervisory or management services. TwinFocus provides investment advisory, wealth management, family office management and administration, institutional consulting, outsourced CIO services, business, and tax planning/structuring, private client wealth structuring, real estate advisory and philanthropic planning services. To engage TwinFocus to provide any of the foregoing services, a Client is required to enter into one or more written Family Office Advisory Agreements (“FOAA”) with TwinFocus setting forth the terms and conditions under which TwinFocus renders its services. For certain Clients and outside investors who are also accredited investors and qualified purchasers, TwinFocus provides access to limited investment opportunities, in many instances related to investments in Qualified Opportunity Zones (“QOZs”), through certain entities that are wholly or partially owned and/or controlled by the Principals of TwinFocus (Wesley Karger, Paul Karger, and John Pantekidis, collectively referred to as the “Principals”), and in some instances, considered separate advisory clients (collectively, referred to as either Special Purpose Vehicles (“SPVs”) or “Affiliated Entities”3).4 The Principals have also created several other Advisory Affiliates primarily to make investments in various passive investments, proprietary equity investments in TwinFocus‐sponsored SPVs and operating businesses.5 In certain situations, these vehicles may receive management fees & carry from these SPVs 1 In accordance with SEC guidance, in determining the amount of TwinFocus’s regulatory assets under management (RegAUM), TwinFocus includes those securities portfolios for which we provide continuous and regular supervisory or management services as of December 31, 2023. 2 TwinFocus classifies assets under advisement separately from RegAUM. We regard assets under advisement (AUA) as assets to which we provide advice or consultation but for which we either do not have discretionary authority or as to which we did not arrange or effectuate the transaction. To illustrate, TwinFocus treats as AUA situations where Client assets are monitored or considered within an overall portfolio construct, for the sole purpose of gaining a holistic perspective of a Client’s financial situation. More specific examples of AUA are private investments to which a Client subscribed before beginning an advisory relationship with TwinFocus or a fee simple interest in residential real estate, as several examples of AUA. 3 Wherever the term “Affiliated Entities” is used in this Form ADV Disclosure, it may mean both “Affiliated Entities” and “Advisory Affiliates”, as defined here and unless stated otherwise. 4 Each of these investment opportunities are also accompanied by subscription agreements, operating/governance agreements, and private offering memoranda, as applicable. 5 Advisory Affiliates are entities created by the Principals to make proprietary investments, inclusive of equity investments in SPVs offered to Clients. Ownership of these Advisory Affiliates is limited to the TwinFocus Principals only. 5 pursuant to their respective investor subscription agreements, governing operating agreements and offering memoranda, as applicable. The Affiliated Entities include TF Realty Partners, LLC and TFRP Mike, LP (collectively referred to as “TFRP”). The TFRP vehicles are separate legal entities with their own governance structures, managed through Boards of Managers, and were established by the Principals, as well as a fourth Managing Partner (William D. Ward), who is also a TwinFocus Advisory Client. Because both TFRP entities as standalone entities do not meet the criteria for registration with the SEC as investment advisers, they are Affiliated Entities of TwinFocus. This Brochure describes the business of TwinFocus. Certain sections also describe the activities of Supervised Persons as well as the business affairs of Affiliated Entities, Advisory Affiliates and related SPVs. Supervised Persons are any of TwinFocus’s principals, officers (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on TwinFocus’s behalf and is subject to TwinFocus’s supervision and control. Wealth Management and Family Office Management Services TwinFocus provides wealth management services (“Wealth Management”) and family office management and administrative services (“Family Office Management”) to its Clients. Wealth Management generally includes: (i) discretionary and/or non‐discretionary Investment Management with respect to identified assets designated in the FOAA (“Investment Management”) and (ii) related analysis of other assets to the extent necessary to allow TwinFocus to provide a holistic solution for an investment portfolio. Family Office Management typically includes Investment Management, as well as wealth structuring, including income, gift and estate tax planning, multi‐generational planning, philanthropic planning, family business and continuity/succession planning, strategic fiduciary services, and family member financial education and family governance services, as applicable. TwinFocus tailors its Investment Management services to the individual needs of each Client initially and on an ongoing basis. To implement its strategic asset allocation recommendations, TwinFocus recommends Clients make investments in third‐party managers and strategies, as well as strategies managed by Affiliated Entities (“Affiliated Entity” or “Affiliated Entities” as the case may be) of TwinFocus, where prudent, suitable, and applicable. Clients, however, are under no obligation to act upon any recommendations made by TwinFocus or to engage the services of TwinFocus’s recommended managers and strategies, including those managed by Affiliated Entities. To the extent TwinFocus has discretionary authority over client accounts, a client’s objectives and guidelines may limit that authority. Before we assume any discretionary authority over a client’s account, we ensure that there is proper authorization in place. Notwithstanding these potential conflicts, TwinFocus only makes investment recommendations and decisions for its Clients in good faith and in a manner that is consistent with its fiduciary obligations, including, but not limited, to the duty of care and loyalty to its Clients, without regard to any potential benefits to itself, its Principals, and/or its Affiliated Entities. 6 Clients are advised that it is their responsibility under their respective FOAA to promptly notify TwinFocus if there are any changes in their financial situations, facts and circumstances, or if they wish to impose new restrictions and/or constraints, which could affect a Client’s investment objectives or necessitate changes to TwinFocus’s wealth management recommendations to such Clients. Client objectives, risk/return preferences, and unique facts and circumstances are initially detailed in the Client FOAAs and subsequently in periodic Client memoranda and other Client Communications. Corporate & Institutional Consulting Services TwinFocus also provides investment and non‐investment related consulting services to various institutions and independent third parties as part of its institutional consulting services. Generally, these services are specialized engagements individually negotiated and based upon the specific scope of work and specific needs and objectives of each institution, where specialized Investment Management Agreements and/or Business Consulting Agreements may be executed, as applicable. In summary, TwinFocus works closely with its institutional Clients to:  Develop/formulate objectives and prudent risk and return profiles, as memorialized in an Investment Policy Statement (“IPS”) or similar communications with an institutional Client, to guide the future investment decision‐making process;  Implement investment strategies in furtherance of an institution’s long‐term goals and objectives, consistent with the institution’s IPS;  Implement a suitable asset allocation model using its manager and strategy selection process;  Help review legal investment documents, negotiate term sheets and fund terms for direct investments and alternative investments, as the case may be;  Proactively work with each institution’s board, trustees, and other authorized representatives in helping those representatives fulfill their fiduciary duties to the institution; and  Monitor, rebalance and report results on a periodic basis, as per the institution’s needs. In addition, TwinFocus: (i) Advises public and private corporations regarding their profit sharing plans, 401(k) plans, defined benefit plans, executive compensation arrangements, and other pools of assets,

on issues such as investment design and review, cost containment, executive/employee retention, and management, such as employee stock ownership plans (“ESOPs”). (ii) Advises private funds, managed, and owned by certain Clients on overall fund structure, investor term sheets, overall income tax structuring and planning, and multi‐generational planning surrounding general partnership and management company interests. TwinFocus’s corporate and institutional consulting services generally are not available to individuals. Such services are memorialized in separate Business Management & Consulting Agreements, as discussed above. 7 Wealth Management Clients can engage TwinFocus to manage all or a portion of their assets on a discretionary basis or a non‐ discretionary basis. TwinFocus primarily allocates Client investment management assets among third‐party managers and investment approaches, in securities and vehicles that include primarily institutional share class mutual funds, where suitable and available, separately managed accounts (SMAs), exchange‐traded funds (ETFs), and to a lesser extent, individual equities, fixed income securities, and structured products, as applicable and suitable. TwinFocus also recommends that certain Clients who are accredited investors as defined under Rule 501 of the Securities Act of 1933 and qualified purchasers as defined under Section 3(c)(7) of the Investment Company Act of 1940 invest in private placement securities and investments. Often these are referred to as “Alternative Investments” and include hedge funds, private equity, venture capital, real estate and direct equity or debt investments in private opportunities which are generally accessed via limited partnerships, limited liability companies, corporate structures, offshore legal entities, and other similar legal structures. Where suitable and available, TwinFocus also recommends offshore/domestic blocker structures for Non‐ US taxable, US taxable (where and when prudent and suitable), and US tax‐exempt Clients. Although many alternative investment opportunities are managed by third party managers not affiliated with TwinFocus (see Use of Independent Managers below), TwinFocus also identifies individual alternative investment opportunities that it deems attractive and that are not offered by independent managers. These strategies/SPVs are typically single‐asset investments in underlying operating companies or real estate investments where TwinFocus or Affiliated Entities play a major management and consultancy role. Examples of such situations include investments in private companies or one‐off real estate development investments. As discussed above, to capitalize on such opportunities as they arise, an Affiliated Entity of TwinFocus in most instances establishes an SPV to provide Clients who choose to participate in such investments the opportunity to access them. These investments are only made to those Clients where such investment is deemed prudent, suitable, and well‐sized within each Client’s investment portfolio and overall balance sheet. TwinFocus also provides non‐discretionary investment management services to Clients relating to their variable annuity, variable and/or guaranteed universal life products, individual employer‐sponsored retirement plan assets, 529 plans, ESOPs, and other products that are often not held by a Client’s primary custodian. In so doing, TwinFocus either directs or recommends the allocation of Client assets among the various investment options that are available within each product and respective platform. Client assets are maintained at the specific underwriting company, product sponsor, or custodian affiliated with the product. Use of Independent Managers Where suitable and available, and only to the extent consistent with a Client’s investment objectives, return expectations and risk tolerances, TwinFocus recommends that a Client allocate some or all Client assets to unaffiliated investment managers (“Independent Managers”). The terms and conditions under which a Client engages Independent Managers generally are set forth in separate written agreements 8 between a Client and the designated Independent Managers. TwinFocus does not receive any remuneration or compensation from such Independent Managers. Investment management fees charged by designated Independent Managers, together with the related fees charged by a Client’s qualified custodian, in most instances are separate from, and in addition to, the advisory fee charged by TwinFocus under a Client’s FOAA. Please see Item 5 for more information concerning advisory and similar fees charged by TwinFocus and Independent Managers. Before making any recommendations concerning Independent Managers, TwinFocus conducts and undergoes a comprehensive quantitative and qualitative due diligence research process that includes reviewing manager due diligence questionnaires and other related materials provided by the Independent Manager or by independent third parties, to obtain information regarding, among other items, the Independent Manager’s investment strategies, management team, past performance, and risk‐adjusted results. TwinFocus also conducts detailed risk‐factor analyses to determine whether clients can obtain the same investment exposure through more liquid, tax‐efficient and cost‐effective securities. Factors that TwinFocus considers in recommending an Independent Manager include a Client’s stated investment objectives, management style and philosophy, portfolio management team, risk‐adjusted performance, reputation, reporting, pricing, expenses, transparency policies, and tax profile. After identifying several Independent Managers whose investment styles and approaches represent a cross‐section of all asset classes within a Client’s strategic asset allocation, TwinFocus provides objective recommendations concerning which Independent Managers to use and sizing of each allocation based on investment fundamentals, both qualitative and quantitative, as well as ongoing monitoring and rebalancing processes. For example, TwinFocus takes steps to monitor the performance and investment fundamentals of each Independent Manager within a Client portfolio on an ongoing basis. TwinFocus rebalances Client portfolios, as necessary, to maintain strategic asset allocations within permissible, predetermined ranges.6 If, however, Independent Managers fail to perform as expected over a period, TwinFocus recommends termination of the Independent Manager and replacement with another similarly situated Independent Manager, in most instances, within the same asset class and style group. In certain situations, TwinFocus makes recommendations to Clients on Independent Managers, where the that Independent Manager is also either a TwinFocus Client, partner, or otherwise affiliated with such Independent Manager. In these situations, this potential conflict of interest is fully disclosed to the Client receiving the recommendation before any recommendation is implemented and acted upon. To emphasize, TwinFocus seeks to identify and select Independent Managers based on objective criteria focused on what is most optimal and best suited for the Client and the Client portfolios. Where potential conflicts exist, such conflicts are fully disclosed to the Client via our Due Diligence memoranda, and/or via other written and oral communications before any recommendations are made and implemented. Investments in Strategies Managed by Affiliated Entities In limited situations, where Clients have expressed a demand for particular private investment opportunities, where unique investment opportunities have been identified and Independent Managers cannot provide access to any such opportunities, TwinFocus through an Affiliated Entity would create an 6 Our approach to rebalancing is described more fully at Item 8, Methods of Analysis, Investment Strategies and Risk of Loss. 9 SPV to provide access to such opportunities on a standalone basis, at the discretion and election of the Client. Such SPVs charge fees and expenses, in addition to any fees TwinFocus receives for its Wealth Management Services, as described above and as described in each Client’s FOAA. These SPV fees are also described in each SPV’s marketing materials, subscription agreements, operating agreements, and offering memoranda, as applicable. For a more detailed discussion on TwinFocus’s establishment and use of SPVs, driven primarily by Client demand for certain risk exposures, please see our discussion on Wealth Management above and related discussion concerning Fees and Compensation in Item 5 and Other Industry Affiliations in Item 10 below. Additions and Withdrawals to Accounts Clients have the ability to deposit additional funds or redeem their account at any time, subject to TwinFocus’ right to terminate an account, as detailed in each Client’s FOAA. Pending notification to TwinFocus, Clients may redeem account assets, subject to usual and customary securities settlement procedures. Clients should note that such redemptions have the potential to impede achievement of their goals because TwinFocus designs Client portfolios based on strategic asset allocations and any untimely material redemption could cause an imbalance in the strategic asset allocation over an indefinite period of time. Additionally, to the extent that TwinFocus allocates a portion of accredited and qualified Client assets to alternative investments that provide limited liquidity, where TwinFocus believes such illiquid investments are suitable, immediate redemptions are not usually available. This is typically the case with certain private investments, including real estate investments, where liquidity typically is not available for several years. Such investments with limited liquidity characteristics are carefully selected and sized for each Client portfolio. We additionally monitor aggregate allocations to such illiquid investments for liquidity management purposes on an absolute basis and vis‐à‐vis the size of Client balance sheets.