RiverFront Investment Group, LLC, is an SEC-registered investment adviser located in Richmond, Virginia. RiverFront was formed in December 2007 and registered with the SEC in February 2008. It is owned primarily by its associates through RiverFront Investment Holding Group, LLC, the holding company for RiverFront. Baird Financial Corporation (“BFC”) is a minority owner of RiverFront Investment Holding Group, LLC, and therefore an indirect owner of RiverFront. BFC is the parent company of Robert W. Baird & Co. Incorporated (“Baird”), a registered broker/dealer and investment adviser. RiverFront has two main lines of business: (1) we offer model investment portfolios, including Fixed Income, Balanced, and Equity model portfolios for a range of investment objectives, risk tolerances, and investment themes (each referred to as an “Investment Solution” or “Investment Strategy”) that can be bought through wrap fee programs at dually registered brokerage and investment advisory firms (“Sponsor Firms”); and (2) we serve as a sub-adviser to certain exchange-traded funds (“ETFs”) and one mutual fund (“Mutual Fund”). Our Mutual Fund and some of our model strategies will invest in RiverFront affiliated ETFs (“RiverFront ETFs”). RiverFront also offers custom portfolio solutions as described in further detail below. Model Portfolios Offered Through Wrap Fee Programs Under wrap fee programs, Sponsor Firms (and the financial advisors at those Sponsor Firms [“Financial Advisors”]) assist their clients with the selection of RiverFront model portfolios (or they have the discretion to select RiverFront model portfolios for their clients) to manage the assets in accounts maintained at the Sponsor Firm, collect RiverFront’s investment advisory fee on behalf of the client (if any), monitor and evaluate RiverFront’s performance, and provide custodial and execution services for the client’s assets. RiverFront provides these portfolios on a discretionary or non-discretionary basis through wrap fee programs to Separately Managed Accounts (“SMAs”), Unified Managed Accounts (“UMAs”), and Model Delivery Platforms (“MDPs”). Offerings listed below are as of the date of this ADV 2A and subject to change. For our current offerings, please visit our website: www.riverfrontig.com and/or contact your Financial Advisor. In wrap fee programs, clients generally pay an asset-based fee to the Sponsor Firm; out of that fee, the Sponsor Firm is responsible for paying an investment advisory fee to RiverFront. In some circumstances, clients will see those fees payable to RiverFront itemized, and in other cases, they will be aggregated together with the fees charged by the Sponsor Firm. Clients participating in wrap fee programs also pay other fees, including certain brokerage charges, as further detailed in Item 5 and Item 12 below, and other custodial or administrative charges. In particular, clients pay additional brokerage commissions and/or an undisclosed markup/markdown when their transactions are stepped out, as described more fully in Item 5. For a more complete description of the fees involved with wrap programs, please see Item 5 of this Brochure and your Sponsor Firm’s Brochure. Typically, RiverFront’s model portfolios are not tailored to the individual needs of clients of Sponsor Firms or Financial Advisors. Each Financial Advisor at a Sponsor Firm can suggest which of RiverFront’s model portfolios is most appropriate for each client. In addition, an individual client’s account can be modified by the Sponsor Firm for certain client-imposed restrictions. In certain circumstances, as determined appropriate by RiverFront, the Financial Advisor, and the client, RiverFront will provide custom investment management services (“Custom Portfolio Solutions”) to the client. Custom Portfolio Solutions are tailored to each client based on the client’s stated investment guidelines and restrictions as provided to RiverFront by the client and Financial Advisor. For more information, please consult your Sponsor Firm. RiverFront’s offerings are described briefly below and in more detail in Item 8 of this Brochure. Different Types of Wrap Fee Program Accounts Clients can access our model portfolios or Custom Portfolio Solutions through wrap fee program SMA, UMA, or MDP accounts at Sponsor Firms. Below is a brief description of each type of account and discussion of how they differ from each other with respect to RiverFront’s offerings. SMAs A separately managed account (“SMA”) is an individually managed account offered by Sponsor Firms through one of their Financial Advisors and managed by an independent investment management firm (the “investment manager” or “manager”). These programs typically offer a wide array of investment managers from which the client can choose. When a client (or a client’s Sponsor Firm with discretion) selects an investment manager for an SMA, the client will usually grant the investment manager full discretion (including trading discretion) over the account. With this authority, the manager directs trading activity in the account according to its investment process and securities selection discipline. Trading discretion requires the investment manager to seek best execution for trades executed in the SMA. Each SMA requires its own custodial account. As a result, a client who chooses to invest with multiple managers maintains multiple custodial accounts at the Sponsor Firm – one for each investment manager selected. If selected to manage the assets in a client’s SMA maintained by a Sponsor Firm, RiverFront will provide investment management services on a discretionary basis to that client in accordance with one or more model portfolios or the Custom Portfolio Solution selected by the client. For more information about RiverFront's trading policies, please see Item 12 of this Brochure. MDPs and UMAs Model Delivery Platforms (“MDPs”) These programs are often referred to as SMA Model Delivery Arrangements, Model Manager Sub-Advisory Arrangements, or Model Delivery Platforms. RiverFront does not operationally distinguish between MDP and UMA accounts (as defined below). Under the typical MDP arrangement, an asset manager like RiverFront will enter into an agreement with the MDP whereby RiverFront delivers its model portfolios to the MDP. Potential users of these model portfolios then enter into subscriber agreements with the MDP to receive access to model portfolios (however, under some arrangements, the end client has an agreement with both the MDP and the model provider). The MDP typically has technology that allows the model portfolio to be applied to multiple accounts and for the model to be delivered, implemented (i.e., traded), rebalanced and updated over time in individual accounts. RiverFront is a model provider to several MDPs. In many instances, these MDPs are selected by wrap sponsors as the required method for asset managers like RiverFront to deliver model portfolios. However, MDPs are not exclusively used by wrap programs; MDPs are also available to third-party registered investment advisers (“RIAs”) who access RiverFront’s models for the benefit of their clients. There can be performance dispersion between accounts where RiverFront has trading discretion and accounts using an MDP (because the MDP has its own trading procedures, which may include, without limitation, proprietary account drift and rebalance protocol, and timing, communication and clearing of market trades, each of which will differ from RiverFront’s). This will cause the models to achieve different performance. Certain RiverFront models are offered on a non-discretionary basis through 55 Institutional Partners, LLC (“55ip”). 55ip is a registered investment adviser that offers access to third-party strategies in addition to other services. RiverFront provides model portfolios to 55ip for use in the

software offered by 55ip. RiverFront will also provide substitute security recommendations for use by 55ip in the implementation of 55ip’s tax management strategies. 55ip receives platform integration, model set up and maintenance, and initial configuration fees from RiverFront. Additionally, 55ip receives a service fee as consideration for the services 55ip provides its customers in relation to the RiverFront Model Portfolios. Similar to our other model delivery arrangements, RiverFront is responsible for the methodology of the model portfolios; but it is not responsible for determining the individual appropriateness or suitability of the model portfolios or any of the securities included therein for any client of 55ip. Additionally, since 55ip is providing a tax management overlay to the model portfolio on an individual account basis; portfolio composition, and as a result account performance, will differ for each investor and may be higher or lower compared to other RiverFront accounts that are invested in the designated model. RiverFront and 55ip are not affiliated. Unified Managed Accounts (“UMAs”) are similar to MDPs, but there are important differences that investors should take the time to understand. A UMA combines all of a client’s assets into a single account. While an MDP account holds the securities associated with a single investment manager in a unique custodial account at the Sponsor Firm, a UMA typically holds multiple investment strategies in the same custodial account, as well as other investment products such as mutual funds, individual stocks, and/or bonds. In a UMA or MDP account, the investment manager delivers an investment model to the Sponsor Firm and often does not have trading discretion over the account. RiverFront is considered to have limited discretion to select investments for accounts through Morgan Stanley Select UMAs. RiverFront does not place trades or exercise trading discretion for these accounts. Clients should speak to their Financial Advisor about the similarities and differences associated with SMAs, UMAs, and MDP accounts so they fully understand their specific account structure. Performance Differences Between RiverFront SMA, UMA, And MDP Accounts While RiverFront SMA, UMA, and MDP accounts utilizing the same Investment Solutions may perform similarly, there are expected to be performance differences between them. There will be performance dispersion between UMAs and MDP accounts as compared to SMAs because RiverFront does not have trading discretion over the UMAs and MDP accounts. (For more information on RiverFront’s trading policies and procedures, please see Item 12 of this Brochure.) Also, Advantage model portfolios (as defined below) have the ability to use fixed income ETPs, individual equity securities, and/or Exchange Traded Products (“ETPs”) to achieve desired investment exposure, whereas ETF Advantage model portfolios (as defined below) use only ETPs. These variances will cause the accounts to achieve different performance. Additionally, Advantage and ETF Advantage portfolios will contain different investments based on their investment guidelines and usage of different investment products as well as other restrictions, and therefore will have different performance results even when utilizing the same Investment Solution. RiverFront Advantage and ETF Advantage Model Portfolios Advantage portfolios are asset allocation portfolios that may be invested in stocks, fixed income ETPs, and third-party ETPs, which include ETFs and exchange-traded notes (“ETNs”). As noted above, Advantage portfolios are offered through wrap fee programs to SMAs, UMAs, or MDPs, depending on the Sponsor Firm. ETF Advantage portfolios differ from Advantage portfolios in that they do not hold individual stocks; rather, they invest only in third-party ETPs. Like Advantage, ETF Advantage portfolios are offered through wrap fee programs to SMAs, UMAs, or MDPs, depending on the Sponsor Firm. RiverShares Model Portfolios RiverShares portfolios are model portfolios that invest in actively managed ETFs that are affiliated with RiverFront (“RiverFront ETFs”); and third-party ETFs. RiverShares portfolios are offered through wrap fee programs to SMAs, UMAs, or MDPs, depending on the Sponsor Firm. RiverFront Custom Portfolio Solutions RiverFront Custom Portfolio Solutions (“CPS”) are portfolio solutions that will typically follow similar investment strategies as Advantage, ETF Advantage, or RiverShares model portfolios but are tailored to each client based on the client’s stated investment guidelines and restrictions as provided to RiverFront by the client and Financial Advisor. As described below, certain CPS Solutions may include holding or having exposure to derivatives, such as option contracts, which may have unique risks to the client’s account. CPS solutions are typically offered through wrap fee programs to SMAs. Sub-Advisor To ETFs and a Mutual Fund RiverFront serves as sub-adviser to certain ETFs and a Mutual Fund. Each is described in more detail below. Certain RiverFront associates, as registered representatives of ALPS Distributors, Inc., actively market the RiverFront ETFs and the Mutual Fund. RiverFront ETFs RiverFront ETFs are actively managed and advised by either ALPS Advisors, Inc. (“ALPS”) or First Trust Advisors, L.P. (“First Trust” and, with ALPS, collectively the “Advisors”) and sub-advised by RiverFront. These ETFs can be purchased individually or as part of RiverShares Model Portfolios or CPS. Each RiverFront ETF pays investment advisory, administrative, distribution, transfer agent, custodial, legal, audit, and other customary fees and expenses, as set forth in the applicable prospectus. These fees and expenses are ultimately borne by the ETF’s shareholders. For more information on the investment objectives, principal risks, and fees associated with the RiverFront ETFs, please see each Fund’s prospectus and statement of additional information (“SAI”), which are available on the Advisors’ websites at alpsfunds.com and ftportfolios.com. RiverFront Sub-Advised Mutual Fund RiverFront serves as sub-adviser to a mutual fund (the “Fund”) that is advised by ALPS. This Fund invests in RiverFront ETFs as well as other third-party ETFs. The Fund pays investment advisory, administrative, distribution, transfer agent, custodial, legal, audit, and other customary fees and expenses, as set forth in the applicable prospectus. These fees and expenses are ultimately borne by the Fund’s shareholders. For more information on the investment objective, principal risks, and fees associated with this Fund, please see the Fund’s prospectus and SAI, which are available on the ALPS website at alpsfunds.com. Assets Under Management As of December 31, 2023, RiverFront’s discretionary assets under management were $751,084,541. RiverFront’s discretionary assets include all assets it manages through SMAs, the Mutual Fund, and RiverFront ETFs. As described above, RiverFront also provides investment advice through third-party MDPs and UMA platforms. In instances where RiverFront has no discretion to affect trades and no supervisory responsibility over the assets in the program, RiverFront does not include these accounts in total AUM, but categorizes them as assets under advisement (AUA). Because RiverFront has only limited discretion over assets managed through Morgan Stanley’s UMA platform, it includes these assets as AUA for purposes of calculating assets under management. As of December 31, 2023, total AUA was $8,851,619,706. On a combined basis, AUM and AUA were $9,602,704,247. Contact us for more information about these accounts.