A. Overview, History and Ownership Freestone Capital Management, LLC (“Freestone,”“us,”“we,” or “our”) is a comprehensive wealth management firm founded in 1999. We are headquartered in Seattle, Washington, and have offices in Santa Barbara, California, San Francisco, California, Campbell, California, and Anchorage, Alaska. Freestone, or our predecessor company, Freestone Capital Management, Inc., has been registered as an investment adviser with the SEC since 1999. Our principal owner is Freestone Capital Holdings, LLC. Gary Furukawa, Freestone’s founder and Chief Investment Officer, and Della Furukawa, indirectly through one or more entities controlled by them, collectively own more than 25%, but less than 50%, of Freestone. Gary Furukawa and Erik Morgan are the managers of Freestone Capital Holdings, LLC and us. For more information regarding who owns and controls Freestone, please see Schedules A and B of Part 1A of our Form ADV. Freestone Investments LLC, our affiliate, is the direct or indirect ultimate general partner of the private funds. To the extent Freestone Investments is deemed to be acting as an investment adviser, it is registered with the SEC as our relying adviser and is identified in Schedule R of Part 1A of our Form ADV. Please see Item 10 (Other Financial Industry Activities and Affiliations) for additional information regarding this and other affiliations. B. Types of Advisory Services We provide ongoing wealth management and investment advisory services to advisory clients on a discretionary or non-discretionary basis, typically through managed accounts. Throughout this Brochure, we refer to clients to whom we provide advice through managed accounts as advisory clients. We also provide asset management and investment advisory services to privately offered pooled investment vehicles, or private funds. The detailed terms, strategies and risks applicable to investors in the private funds are described in each private fund’s organizational and offering documents. The private funds and advisory clients are collectively referred to in this brochure as our clients. C. Tailoring our Advisory Services and Investment Solutions Through our discussions with each advisory client, we develop a wealth management and investment plan for that advisory client based on, among other things, the advisory client’s particular circumstances, financial goals or objectives, risk tolerance, time horizon and liquidity needs. We then manage that advisory client’s assets using a combination of one or more of the following investment solutions: FREESTONE

CAPITAL MANAGEMENT, LLC Page 3 ▪ Internally managed model portfolios developed by us; ▪ Model portfolios developed by parties not affiliated with us and managed by us or by those unaffiliated parties; and ▪ Alternative investments, including investments in the private funds and funds not managed or controlled by our affiliates or us. We manage most assets on a discretionary basis, meaning we have investment control to implement the investment plan we have developed with an advisory client without obtaining the advisory client’s consent prior to making a trade or allocation. For advisory clients, typically this involves allocating the advisory client’s assets among the above-described investment solutions. For the private funds, this generally involves investing a private fund’s assets in accordance with the private fund’s organizational and offering documents. Advisory clients may impose reasonable restrictions on the way we manage assets held in their accounts, such as prohibiting the purchase of tobacco stocks. The determination as to what is a “reasonable restriction” is solely ours. To the extent that an advisory client imposes a restriction that would impact our ability to implement the strategy for that account, we reserve the right to refuse to manage or liquidate the account. We only make recommendations to advisory clients regarding investing in the private funds on a non-discretionary basis, meaning that an advisory client must decide on a case-by- case basis whether to accept or reject our recommendations regarding making an investment in a private fund. We manage the private funds on a fully discretionary basis. Investors in the private funds generally cannot impose restrictions on the way we manage the private funds or the assets held by the private funds. Investors in the private funds are not considered our “clients” solely by virtue of their investment in one or more of the private funds. In addition to the above services, we also provide general financial advice, wealth planning and other services not specifically related to investment activity. See the “Wealth Management and Financial Planning” portion of Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) for additional information regarding these services. D. Wrap Fee Programs We do not participate in wrap fee programs. E. Assets Under Management As of December 31, 2022, our total regulatory assets under management were approximately $8,221,070,000. Of this amount, we managed approximately $6,104,439,000 on a discretionary basis and approximately $2,116,631,000 on a non- discretionary basis. FREESTONE CAPITAL MANAGEMENT, LLC Page 4