A. Description of the Firm: Morton Capital Management, LLC, doing business as Morton Wealth (“Morton”), is a California limited liability company and is owned by members of Morton’s management and executive team. The Managing Members of Morton are Meghan Pinchuk, Jeffrey Sarti, Stacey McKinnon and Eric Selter. Morton was founded in 1981 and registered as an investment adviser with the Securities and Exchange Commission in 1983. As of December 31, 2023, Morton managed $2,645,038,579in total assets, $2,623,135,398 of which is managed on a discretionary basis and $21,903,181on a non-discretionary basis. B. Types of Advisory Services Offered: Investment Advisory Services Morton provides customized investment advisory and financial planning services, with a goal of building long-term relationships based on trust. Morton designs and implements standardized investment strategies based on general investment guidelines provided by its Investment Committee. Each client portfolio is then customized to consider a client’s unique objectives, including goals, risk tolerance, time horizon, liquidity needs and concerns. Morton places an emphasis on managing risk with the objective of reducing volatility. In order to provide clients with more objective advice, Morton operates on a fee-only basis and does not accept commissions from any source. Generally, Morton provides investment advisory services on a discretionary basis.1 For more information on discretion, please see Item 16, “Investment Discretion.” Morton’s investment advisory services usually include, but are not limited to:  Analyzing a client’s current financial situation and prior investment experience  Helping clients set goals to determine the appropriate time horizon, investment objectives, and amounts of money needed to accomplish investment goals  Reviewing a client’s risk profile to help define the tolerance for risk  Designing and implementing an asset allocation strategy by selecting appropriate asset classes and determining how to allocate investable funds among those asset classes. 1 “Discretionary basis” means that Morton has the power to buy and sell securities in a client’s accounts without previously notifying the client. However, decisions are made based on a client’s investment strategy and restrictions. Morton Wealth Page 5 of 42  Monitoring performance of funds and managers  Performing ongoing analysis of a client’s portfolio performance  Modifying and rebalancing portfolios based on a client’s changing needs and Morton’s analysis of individual portfolio performance  Assessing applicable market and economic conditions While Morton generally manages client assets on a discretionary basis, in certain circumstances Morton provides services on a limited discretionary or non-discretionary basis. As described above, Morton customizes its advisory services to a client’s individual needs and invests within any communicated restrictions that are placed on the types of securities within a portfolio. Private Funds: Morton also provides the following investment advisory services to pooled investment vehicles: RBE Capital Partners Fund, LP RBE Capital Partners Fund LP ("RBE " or the "Fund") was formed in August 2010. Pursuant to RBE's Amended Limited Partnership Agreement, Morton replaced the original General Partner and became the successor General Partner effective as of August 31, 2021. Morton serves as the General Partner and provides investment advisory services to RBE but will not charge a management fee or receive any compensation for its role as General Partner and manager. Other than cash, RBE’s sole asset is a promissory note. RBE is not open to new investors. M83 Income Fund, LLC Morton, through a wholly owned subsidiary, acts as the Manager and investment adviser to the M83 Income Fund, LLC (“M83”). M83 will invest primarily in underlying private investments with managers that pursue various credit-related strategies, either directly into their funds or through co-investment opportunities offered by such managers. To the extent that Morton’s individual advisory clients qualify, they will be eligible to participate as investors of M83. All relevant information, terms and conditions relative to an investment in M83, including the compensation received by Morton or its affiliates as Manager, suitability, risk factors, and potential conflicts of interest, are set forth in a Private Placement Memorandum (the “PPM”), LLC Agreement (the “LLCA”), and/or Subscription Agreement (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in M83. Please see Item 5- Fees and Morton Wealth Page 6 of 42 Compensation, and Item 10- Other Financial Industry Activities and Affiliations, for additional information regarding the Private Funds. Independent Managers: In some cases, Morton recommends to Clients that all or a portion of their portfolio be implemented by utilizing one or more unaffiliated money managers. Access to Independent Managers may be provided by Morton through a sub-advisory relationship between Morton and the Independent Manager, and/or through a direct contractual engagement between the Client and the Independent Manager. Clients may be required to enter into a separate advisory agreement directly with the Independent Manager selected, which is in addition to the agreement entered into between the client and Morton. Morton will serve as the Client’s primary advisor, assisting and advising the Client in establishing investment objectives for the account[s], the selection of the Independent Manager[s], defining any Client investment restrictions and other support with respect to the account[s]. The Independent Manager[s] will have the discretion over the investments in the account[s] and will manage the account[s] consistent with the stated mandates of the strategy. In consideration for such services, the Independent Managers will charge their own respective fees, which are separate and in addition to Morton’s fees. The Independent Manager may assume responsibility for fee billing, and fees are generally billed separately from fees charged by Morton. Morton will not receive different levels of compensation or any additional fees depending on the Independent Manager selected. Financial Planning Services: Financial planning services on various levels are provided upon request to Morton’s new and existing investment management clientele and are generally performed as a part of Morton’s investment advisory services. Financial planning services are offered on a comprehensive or limited focus basis supported by an analysis of the client’s current situation, goals, and objectives. Information is obtained through personal interviews and the review of related documents and data supplied by the client. After receipt of all requested documents and the performance of financial planning reviews by Morton personnel, a written financial plan is prepared and provided to the clients. The implementation of financial plan recommendations is entirely at the discretion of the client. Our financial planning services include, but are not limited to, one or more of the following areas: i. Financial Goals Morton Wealth Page 7 of 42 Morton helps clients identify financial goals and develop a plan to reach them. This includes identifying their financial goals, the necessary resources to achieve them, how much time they will need to reach them, and how much they should budget for each goal. ii. Retirement Planning Morton’s retirement planning services typically includes projections of the client's likelihood of achieving financial independence. For situations where projections show less than the desired results, Morton will suggest various ideas to consider in order to achieve the desired results. On occasion, these suggestions will impact the original projections by adjusting certain variables (i.e., working longer, saving more, spending less,

taking more risk with investments). If the client is near retirement or already retired, advice is given on appropriate distribution strategies, seeking to minimize the likelihood of running out of money or having to adversely alter spending during their retirement years. iii. Estate Planning Review While Morton does not provide any legal advice, Morton’s review usually includes an analysis of the client's exposure to estate taxes and their current estate plan, which includes a review of their will, powers of attorney, trusts and other related documents as applicable. In most cases, the analysis of estate plan documents such as wills and trusts will be conducted internally by Morton but may sometimes be conducted by an independent estate planning attorney. Recommendations based on this analysis are provided to the client in a written review document. Recommendations occasionally include ways for the client to manage future estate taxes by implementing estate planning strategies and suggestions for the amendment or redrafting of trust documents or wills. iv. Insurance Review In most cases, this review will be conducted internally by Morton employees or for more complex needs, this analysis may be performed by an independent insurance professional. Morton will conduct a review of existing policies in order to examine coverage in areas such as life, health, disability, long-term care, liability, home and automobile. Regarding estate and tax planning, Morton and its professionals are not attorneys, insurance professionals or accountants, and no portion of Morton’s services should be interpreted as legal, insurance or accounting advice. You should not rely solely on information, considerations or recommendations provided by Morton, and should consult with your Morton Wealth Page 8 of 42 attorney, insurance professional or accountant before implementing any transactions or strategies. At its discretion, Morton may offer certain new clients more limited financial planning services, which will only include retirement planning using cash flow projections as described above. Clients will generally acknowledge the scope of the financial planning services to be provided as part of a written agreement with Morton. Retirement Plan Advisory and Consulting Service: Morton also provides retirement plan advisory and consulting services to employer plan sponsors on an ongoing basis. Morton provides the following services to its plan clients: Pension/Retirement Plan Consulting Services:
• Plan Fiduciary Services
• Communication and Education Plan Fiduciary Services- Morton generally serves as a 3(21) Fiduciary in support of the Plan Sponsor to ERISA Plans, depending on the terms of the agreement with the Plan. Morton provides the following Plan Fiduciary Services under the terms of the Advisor's agreement with each Plan:
• Employee Enrollment and Education
• Performance Reporting
• Ongoing Investment Recommendation and Monitoring Communication and Education- Morton provides Communication and Education to the Plan and its Participants, pursuant to the terms of the Advisor’s agreement with each Plan:
• Investment education
• Periodic on-site advisor visits with Plan participants for account updates and reviews
• Periodic Participant group education opportunities “Strategist”- Business Consulting Services: Business clients may also engage Morton to provide consulting services tailored to each business’ needs. Business consulting services provided by Morton (referred to as Morton’s “Strategist” offering) include: Morton Wealth Page 9 of 42
• Business valuation estimates;
• Exit and succession planning;
• Cash flow planning and liquidity analysis;
• Governance recommendations;
• Coordination of non-affiliated financial, tax and legal professionals;
• Personal financial planning; and
• Private networking opportunities “Strategist” Consulting services are agreed upon by both parties prior to undertaking the desired service. Clients will sign an agreement which outlines the specific services to be provided by Morton and its associated personnel. “Modearn” by Morton- Financial Planning & Advice and Investment Advisory Services: Morton will provide financial planning and investment advisory services to “next-gen” clients (generally aged 25 - 55) who are still growing their net worth and want to balance their future goals with enjoying life today. This offering will be referred to as Morton’s “Modearn” offering. Modearn clients will be provided with financial education and advice in a variety of areas, including:
• Spending Strategies: development and ongoing support of a spending strategy that incorporates saving for education and retirement, managing debt, property purchases, and career and tax planning.
• Portfolio Design: education around behavioral finance, values-based investing, and stock options/restricted stock allocations.
• Asset, Income & Personal Protection: education around personal insurance policies, estate planning opportunities, and business/asset ownership.
• Debt & Credit Management: provide referrals to mortgage brokers and small business loan options, evaluate and recommend options for credit maintenance & credit card options. Modearn clients will generally receive the investment advisory services described in Item 4(B) above in addition to financial planning education and advice. Morton Wealth Page 10 of 42 Modearn planning and investment advisory services are agreed upon by both parties prior to undertaking the desired service. Clients will sign an agreement which outlines the specific services to be provided by Morton and its associated personnel. C. Types of Securities: Morton utilizes a variety of securities when constructing client portfolios. Morton believes that portfolios should contain various assets that are not all correlated to one another, and thus utilizes alternative investments in an effort to seek diversification benefits in addition to the traditional asset classes of cash, fixed income and equities in client portfolios. For purposes of these categorizations, equities are defined to include common stocks, exchange traded funds (“ETFs”), equity mutual funds, publicly traded master limited partnerships, and publicly traded real estate investment trusts (“REITs”). Fixed income investments include government bonds, municipal bonds, corporate bonds, high yield bonds, foreign bonds, fixed income mutual funds, and structured notes. Alternative investments include private investments in limited liability companies or limited partnerships (e.g., private investment funds) that include, but are not limited to, strategies such as real estate equity, private lending, or private equity, among others. Cash represents either money market funds or cash equivalents. A large portion of clients’ portfolios are invested in retail and institutional share class mutual funds and ETFs. Morton also utilizes interval funds for its investment portfolios. When appropriate, Morton presents certain clients with opportunities to invest in private investments in limited liability companies, limited partnerships, or other alternative strategies (together “private funds”). Private fund investment opportunities are not available to all clients and are based on several factors, including but not limited to, a client’s sophistication, risk tolerance and qualifications, net worth, investment objectives, and amount of assets in client account(s). In limited situations, or upon request, such as for some large accounts or accounts with a specific concentrated stock position, Morton will also employ options strategies such as covered calls. These strategies require margin accounts and are subject to additional risks. See Item 8 below for additional details and a discussion of the specific risks involved in the above strategies. Morton Wealth Page 11 of 42