A. Aviance Capital Partners, LLC (“Aviance”) is a Florida limited liability company, which was formed and registered as investment adviser in March 2008. Aviance is principally owned by Jack D. Brown, Managing Member, and Jeffrey S. Pike, Member and Chief Compliance Officer. Aviance provides investment advisory services on a discretionary or non-discretionary basis to its clients, who generally include individuals, high net worth individuals, trusts, estates, pension and profit-sharing plans, corporations, and other business entities. B. INVESTMENT ADVISORY SERVICES Clients can engage Aviance to provide discretionary or non-discretionary investment advisory services according to the terms and conditions of an Investment Advisory Agreement. Aviance’s annual investment advisory fee incorporated into that agreement is based upon a percentage of the market value of the assets placed under its management. Aviance’s investment advisory services are specifically tailored to the needs of each client. To begin the process, an investment adviser representative will collaborate with the client to develop investment objectives based upon an assessment of factors that typically include risk tolerance, liquidity requirements, client preferences, and investment restrictions. Once the client’s investment objectives are established, Aviance will allocate or recommend the client allocate investment assets consistent with the designated investment objectives and the strategy agreed upon between the client and their investment adviser representative. Once allocated, the client’s account is typically managed according to the selected strategy for which Aviance may execute account transactions based on ongoing reviews or other triggering events. Further, investment adviser representatives will periodically discuss with clients whether a strategy remains appropriate for them. Aviance generally allocates client investment assets in conformity with one or more investment strategies described below, which will all be monitored and periodically adjusted to suit market conditions based on internal research. The corresponding fee schedules associated with these strategies are provided in Item 5.A. Disciplined Growth: This strategy invests in equities that Aviance perceives as being high quality, which are based on domestic and international companies with generally large market capitalizations. Disciplined Value: This strategy utilizes a value investing approach of stock selection to invest in equities of predominantly domestic companies with varying market capitalizations. Global: This strategy invests primarily in closed end funds and exchange traded funds (“ETFs”) that consist of equity securities in both international and domestic markets. Dividend Plus: This strategy invests in large capitalization, dividend paying stocks that Aviance perceives to be high quality. Enhanced Income: This strategy invests in diversified income-producing securities within asset classes that Aviance perceives as having the best potential for risk-adjusted income. Core Plus Fixed Income: This strategy invests primarily in closed end funds and ETFs that consist of fixed income securities. Traditional Bond Portfolios: This strategy invests in fixed income securities that are designed to provide a regular, stable income stream such as bonds issued by federal governments, local municipalities, or corporations. Aviance’s annual investment advisory fee compensates for investment management services and financial planning services that are ancillary to the investment management process. There is no additional cost associated with the financial planning services, which may address, for example: cash flow, retirement needs, asset allocation consulting, educational funding, tax efficiency, charitable gifting, estate considerations, risk/insurance management, wealth transfer, and other special needs. Aviance provides these services as appropriate during the investment advisory process but is not obligated to provide these services with any regularity or according to a set schedule unless specifically agreed with the client. Clients who own variable annuities can also generally engage Aviance to manage their variable annuity subaccounts as part of their overall investment portfolio. A variable annuity is a deferred annuity that provides investment returns based on the performance of its “subaccounts.” Those subaccounts contain investment assets. Unless otherwise agreed in writing, the value of the subaccounts that clients engage Aviance to manage would be included as part of Aviance’s calculation of its investment advisory fee described in Item 5. Aviance’s investment selection for the variable annuity subaccounts is limited to those made available by the respective variable annuity sponsor. While neither Aviance nor any of its employees are registered as or associated with a broker-dealer, certain of Aviance’s investment adviser representatives are licensed insurance agents. When Aviance deems it consistent with a client’s investment objectives and financial situation, clients may purchase or exchange certain variable annuities that are made available through those insurance agents, who will not earn or accept any commission compensation from such purchase or exchange. Aviance’s representatives will not receive any individual compensation from the sale or exchange of variable annuities. Aviance’s only compensation related to variable annuities will be limited to the asset-based fee it earns from managing the investment subaccounts it is engaged to manage, as further described in Item 5 below, or as part of financial planning services that the client may engage Aviance to provide . Clients are not under any obligation to engage Aviance to provide any of the above services. The fact that Aviance could earn an advisory fee on the variable annuity subaccounts presents a conflict of interest if Aviance were to recommend that clients evaluate variable annuity products with unaffiliated broker-dealers/insurance agencies. Aviance mitigates that conflict of interest by reminding clients that they are not under any obligation to purchase variable annuities or engage Aviance to manage variable annuity subaccounts. myAviance Program Overview When consistent with client’s investment objectives, Aviance may offer asset management services through the myAviance program (the “myAviance Program”), an automated investment program through which clients are invested in a range of investment strategies that Aviance constructed and manages, each consisting of a portfolio that can include ETFs, mutual funds, and a cash allocation. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co.”). Aviance uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the myAviance Program. Aviance is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (CS&Co. and its affiliates are sometimes collectively referred to as “Schwab”). Aviance, and not Schwab, is the client’s investment adviser and primary point of contact with respect to the myAviance Program. As between Aviance and Schwab, Aviance is solely responsible, and Schwab is not responsible, for determining the appropriateness of the myAviance Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. Clients can instruct Aviance to exclude up to three mutual funds or ETFs from their portfolio. Aviance contracted with SPT to provide Aviance with the Platform, which consists of technology and related trading and account management services for the myAviance Program. The Platform enables Aviance to make the myAviance Program available to clients online and includes a system that automates certain key parts of its investment process (the “System”). The System includes an online questionnaire that helps Aviance determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Aviance will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but Aviance then makes the final decision and selects a portfolio based on all the information it has about the client. The System also includes an automated investment engine through which Aviance manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). Aviance charges clients a fee for its services under the myAviance Program as part of the fees described under Item 5, Fees and Compensation. Aviance’ fees are not set or supervised by Schwab. Aviance does not pay SPT or Schwab fees for the Platform as long as it maintains $100 million in client assets in accounts at Schwab that are not enrolled in the myAviance Program. This arrangement presents a conflict of interest as it provides an incentive for Aviance to recommend that clients maintain their accounts at Schwab. Aviance would therefore generally recommend clients maintain accounts at Schwab if consistent with the considerations discussed in Item 12 below, which mitigates this conflict of interest. Clients enrolled in the myAviance Program are limited in the universe of investment options available to them. For example, the investment options available are limited to ETFs, mutual funds, and cash/cash equivalents, whereas Aviance can recommend various other types of securities in its other services. Clients will have access to their accounts and a financial interface online but can also confer with Aviance with respect to their account. Please also refer to Item 8 below with respect to the investment risks associated with the myAviance Program, including mutual fund and ETF risk. Rebalancing The System will rebalance a client’s account periodically by generating instructions to Schwab to buy and sell shares of funds and depositing or withdrawing funds through the “Sweep Program,” considering the asset allocation for the client’s investment strategy. Rebalancing trade instructions can be generated by the System when (i) the percentage allocation of an asset class varies by a set parameter established by Aviance, (ii) Aviance decides to change the ETFs or their percentage allocations for an investment strategy or (iii) Aviance decides to change a client’s investment strategy, which could occur, for example, when a client makes changes to their investment profile or imposes or modifies restrictions on the management of their account. Accounts below $5,000 may deviate farther than the set parameters as well as the target allocation of the selected investment profile. Rebalancing below $5,000 may impact the ability to maintain positions in selected asset classes due to the inability to buy or sell at least one share of an ETF or mutual fund. For example, withdrawal requests may require entire asset classes to be liquidated to generate and disburse the requested cash. Sweep Program Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a minimum of 4% of an account’s value to be held in cash, and may be higher, depending on the investment strategy chosen for a client. The Cash Allocation will be accomplished through enrollment in the Sweep

Program, which is sponsored by Schwab. By enrolling in the myAviance Program, clients consent to having the free credit balances in their brokerage accounts at Schwab swept into deposit accounts (Deposit Accounts) at Charles Schwab Bank (Schwab Bank) through the Sweep Program. Schwab Bank is an FDIC-insured depository institution that is a Schwab affiliate. The Sweep Program is a required feature of the myAviance Program. If the Deposit Account balances exceed the Cash Allocation for a client’s investment strategy, the excess over the rebalancing parameter will be used to purchase securities as part of rebalancing. If clients request cash withdrawals from their accounts, this likely will require the sale of fund positions in their accounts to bring their Cash Allocation in line with the target allocation for their chosen investment strategy. If those clients have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In accordance with an agreement with Schwab, Schwab Bank has agreed to pay an interest rate to depositors participating in the Sweep Program that will be determined by reference to an index. Compensation to Schwab under the myAviance Program Clients do not pay fees to SPT or brokerage commissions or other fees to Schwab as part of the myAviance Program. However, Schwab receives other revenues including but not specifically limited to the following which is subject to change: (i) the profit earned by Charles Schwab Bank, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that Aviance selects to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from third- party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. Pontera Platform / Order Management System Aviance uses a platform provided by Pontera Inc. (“Pontera”) to manage held away accounts such as 401(k), 403(b), profit-sharing plan accounts, and defined contribution plan accounts (collectively, “held away accounts”). The Pontera platform allows Aviance to manage client accounts on a discretionary basis without having to obtain and maintain a client’s login credentials. Clients using the Pontera Platform will receive a link allowing them to connect their account(s) to the platform. Once a client account is connected to the Pontera platform, Aviance will monitor and rebalance or reallocate investments in that account in the same way as it does for other (non-held away) accounts, though using different tools. When clients engage Aviance in this capacity, they are responsible to keep the Pontera platform link active, so that Aviance will be able to access and manage the respective account without delay. If Aviance determines that a Pontera platform link has become inactive, Aviance will use its best efforts to notify the client to resolve the issue. However, clients will remain subject to Aviance’s fees described in Item 5 even when Aviance is not capable of executing trades because of an inactive link. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND ALONE) Aviance may agree to provide financial planning and consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand- alone separate fee basis. Before engaging Aviance to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Aviance 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 before Aviance commences services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Aviance does not serve as a law firm, accounting firm, or insurance agency, and no portion of Aviance’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, Aviance does not prepare estate planning documents or tax returns. Unless specifically agreed in writing, neither Aviance nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with Aviance, if desired. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from Aviance and its representatives in that respect. Aviance’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. To the extent requested by a client, Aviance may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.), including Aviance’s representatives in their separate and individual capacities as licensed insurance agents more fully described in Items 5.E. and 10.C. below. Clients are under no obligation to engage the services of any recommended professional, who are responsible for the quality and competency of the services they provide. Clients are not obligated to purchase insurance commission products through such a representative. Clients may purchase insurance products recommended by Aviance through other non-affiliated insurance agents. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective 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 the former employer’s plan, if permitted, (ii) roll over the assets to the 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). If Aviance recommends a client roll over their retirement plan assets into an account to be managed by Aviance, such a recommendation creates a conflict of interest if Aviance will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Aviance. ERISA / IRC Fiduciary Acknowledgment. When Aviance provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way Aviance makes money creates some conflicts with client interests, Aviance operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, Aviance must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure Aviance gives advice that is in the client’s best interest; charge no more than is reasonable for Aviance’s services; and give the client basic information about conflicts of interest. Portfolio Activity/Inactivity. There may be extended periods of time when Aviance will not execute any transactions in a client’s portfolio. In addition, certain of Aviance’s investment strategies may involve above-average portfolio turnover which could negatively impact upon the net after-tax gain experienced by an individual client in a taxable account. Regardless of the level of activity in a client’s account, they remain subject to the fees outlined in Item 5. Client Obligations. When performing its services, Aviance is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify Aviance if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending Aviance’s services or previous recommendations. C. Aviance provides investment advisory services tailored to the specific needs of each client. Before providing investment advisory services, an investment adviser representative will coordinate with clients to develop their investment objectives. Aviance will then allocate or recommend that clients allocate investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on Aviance’s services. D. Aviance does not offer a wrap fee program for its investment advisory services. However, Aviance is a participating investment adviser in the “Lockwood Investment Strategies” wrap fee program sponsored by Lockwood Advisors, Inc., an unaffiliated SEC-registered investment adviser (the “Wrap Program Sponsor”). Participants in this wrap-fee program will enter into a separate agreement with the Wrap Program Sponsor and pay their fees directly to the Wrap Program Sponsor (who, in turn, will remit a portion of those fees to Aviance). The advisory fees remitted to Aviance are based upon an annual percentage of assets under management and are calculated by the Wrap Program Sponsor either on a quarterly basis or a monthly basis. Wrap Programs. If Aviance is engaged to provide investment advisory services as part of an unaffiliated wrap-fee program, Aviance will be unable to negotiate commissions and/or transaction costs. Under a wrap fee program, the applicable wrap fee program sponsor arranges for the participant to receive investment advisory services, the execution of securities brokerage transactions, custody, and reporting services for a single specified fee. Participation in a wrap fee program may cost the participant more or less than purchasing such services separately. Since the custodian/broker-dealer is determined by the applicable wrap fee program sponsor, Aviance will be unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result, participants may pay higher commissions or other transaction costs or greater spreads or receive less favorable net prices on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by Aviance. Higher transaction costs adversely impact account performance. Aviance’s Chief Compliance Officer, Jeffrey Pike, remains available to address any questions that a client may have regarding participation in a wrap fee program. E. As of December 31, 2023, Aviance had $628,607,744 in assets under management on a discretionary basis; and $3,682,479 in assets under management on a non-discretionary basis.