A. Description of Your Advisory Firm Chicago Partners Investment Group LLC, d/b/a Chicago Partners Wealth Advisors (“CP” and/or “the firm”) is an Illinois limited liability company and an independently owned SEC-registered investment advisor. The firm is headquartered in Chicago, IL. The firm was founded in 2009 by James Hagedorn, CFA (Managing Partner), and co-founded by Anthony Halpin, CPA (Partner). Mr. Hagedorn is the majority and principal owner of CP. B. Description of Advisory Services Offered CP offers discretionary and non-discretionary investment advisory services to high-net-worth individuals, trusts, not-for-profit plans, endowments, charitable organizations, corporations, other business entities. CP’s advisory services may include financial planning, portfolio management, selection of other advisers, and 401(k) plan option review and monitoring. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of CP), CP may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. B.1. Portfolio Management Services B.1.a. Separately Managed Accounts CP advises on the assets of its clients based on their selected investment strategy in accordance with their investment objectives, risk tolerance, time horizon, and any reasonable restrictions they impose.  Step 1 – Analyze Current Portfolio. We review the client’s current investment portfolio. Through the Wealth Management System (WMS), we can aggregate in current holdings, which include investments that we will manage as well as investments the client plans to keep with other managers. We will analyze this information to help determine areas that may be lacking in diversification as well as areas that hold underperforming or high fee investments. We partner with clients to be their General Manager in making sure all their investments work in concert together.  Step 2 – Design Optimal Portfolio. We design an optimal portfolio for the client based on outside holdings, cash needs and risk profile. Using our analysis of the client’s current portfolio as well as discussions and meetings with the client, we will design a portfolio that meets the client’s investment goals and objectives. This is a customized process and the portfolio will be designed so that it is unique to the client’s specific situation.  Step 3 – Investment Advisory Agreement. We formalize the investment relationship with the client. Through a disciplined, ongoing and collaborative approach, we will build with the client a comprehensive strategic asset allocation with asset class targets that we will manage to maintain.  Step 4 – Build Portfolio. We build the client’s portfolio. We will provide the client with the necessary documents to open the appropriate investment accounts at one of the custodians that we partner with. We will then facilitate the transfer of assets from other custodians or help the client deposit funds to their accounts. Once the accounts are funded, we will outline the appropriate trading strategy. We will then place the trades on the client’s behalf based on our agreed upon trading strategy.  Step 5 – Monitor and Review. We monitor and review the client’s portfolio. As soon as the new accounts are open, the client will begin receiving monthly statements from the custodian. The client will also receive a custom quarterly reporting package from us that provides economic updates, asset allocation overview, performance data and relevant tax related information. We also have the ability to produce custom reports on an as-needed basis to help the client stay up to date with their portfolio and to help us continually monitor how the portfolio is performing. We will review the portfolio with the client when desired and will make appropriate changes as needed. In addition to providing CP with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are required to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Before engaging CP to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with CP setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. On a quarterly basis, CP’s reports to clients will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. CP will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. B.2. Family Office  Step 1 - Provide Comprehensive Performance Reporting. We will aggregate all investment accounts. We will provide a consolidated "One Page" investment summary of each account relative to their appropriate benchmark, as well as performance information by asset class and security.  Step 2 - Provide Comprehensive Asset Allocation Reporting. We will create a comprehensive asset allocation statement breaking down an aggregated investment portfolio by asset class relative to strategic targets.  Step 3 - Provide Recommendations on Asset Allocation Changes. Based on information generated in steps 1 & 2 above, we will recommend changes in the asset allocation to make sure the family has real diversification and is positioned to meet their investment objectives. Importantly, we will work with each family member to make sure their investment program complements the comprehensive investment portfolio for the family.  Step 4 - Provide Recommendations on Manager Changes. Based on the information in Steps 1, 2 & 3, we will recommend changes to existing managers/investments and also recommend new mangers/investments to help the portfolio maximize after tax returns for a given level of risk.  Step 5 - Provide Insights & Ongoing Guidance On How to Drive Down Overall Investment, Reporting & Implementation Fees and Costs. Fees matter significantly. We help Family Offices dramatically reduce unnecessary fees and expenses through our unique approach to drive down investment manager, investment advisory, trading and tax costs. B.3. Consulting Services CP may be engaged to provide specified consulting services. During or upon completion of any such services, CP may, if requested by the client, recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from CP. However, if a client engages the services of any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not CP, shall be responsible for the quality and competency of the services provided. B.4. Retirement Plan Consulting Services CP may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Consulting Agreement between CP and the plan. For such engagements, CP may assist the Plan sponsor to select an investment platform from which Plan participants shall make their respective investment choices, and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision making process. B.5. 401(k) Savings & Retirement Plan Services CP provides investment education and advice to eligible employees and participants of 401(k)/profit sharing plans. The firm provides advice on investment choices and strategies through meetings conducted once annually with each of the participant groups. If requested to do so, CP shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, CP shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. CP ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. CP will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify CP of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by the CP to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of CP calculating its advisory fee. B.6. Chicago Partners Optimized Intelligent Portfolio Program Program Overview When consistent with a client’s investment objectives, CP may offer portfolio management services through the Chicago Partners Optimized Intelligent Portfolio Program (the “Program”), an automated investment program through which clients are invested in a range of investment strategies CP has constructed and manages, each consisting of a portfolio of exchange-traded funds (“ETFs”), mutual funds and a cash allocation. The client may instruct CP to exclude up to three funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co.”). CP 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 Program. CP is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (CS&Co., Charles Schwab Bank and their affiliates are collectively referred to as “Schwab”). CP, and not Schwab, is the client’s investment adviser and primary point of contact with respect to the Program. As between CP and Schwab, CP is solely responsible, and Schwab is not responsible, for determining the appropriateness of the 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. CP has contracted with SPT to provide CP with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables CP to make the 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 CP determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that CP will recommend a portfolio through 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 CP 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 CP manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). CP charges clients a fee for its services as described below under Item 5. CP’ fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does receive other revenues in connection with the Program, which are described in the “Compensation to Schwab Under the Program” section below. CP does not pay SPT fees for the Platform Clients enrolled in the 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 whereas CP recommends various other types of securities in its other services. The Program is designed to provide guidance and professional assistance to individuals who are beginning the process of accumulating wealth. Clients will have access to their accounts and a financial interface online but will also have the opportunity to confer with CP with respect to their account. Rebalancing The System will rebalance a client’s account periodically by generating instructions to CS&Co. 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 CP, (ii) CP decides to change asset allocation percentages for an investment strategy or (iii) CP 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. Compensation to Schwab Under the Program Clients do not pay fees to SPT or brokerage commissions or other fees to CS&Co. as part of the Program. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, a Schwab affiliate, 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 CP 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. B.7 Affiliated Private Funds In August 2021, the Firm launched two private investment funds, Diversified Equity Fund LLC (“DEF”) and Diversified Income Fund LLC (“DIF”) (collectively, the “Fund[s]”), the underlying investments of which are comprised primarily of liquid mutual funds and ETFs. Custody of the Funds is maintained at Schwab. The Funds maintain a daily and monthly Net Asset Value. The purpose of the Funds is to serve employees of public CPA firms who were previously restricted from investing in such funds because the CPA firm serves as the fund auditor. CP is compensated at the Fund level only. No performance or incentive related compensation is payable to the Firm or any of its affiliates. Each Fund client receives a monthly statement from an independent fund administrator and a certified annual financial statement prepared by a PCAOB auditor. The terms and conditions for participation in the Funds are set forth in the Fund’s offering documents which will be presented to each prospective Fund investor. As noted above, CP is the investment adviser to DIF (or the “Income Fund”) and DEF (or the “Equity Fund”) which are unregistered investment companies organized as limited liability corporations. CP is affiliated with each of these funds and CP’s Principal, James Hagedorn, serves as the General Partner to each fund. The complete description of each fund (including the terms, conditions, risks, conflicts and fees) is set forth in the respective fund’s offering documents. The DEF Fund’s investment objective is maximum capital growth during periods of favorable market conditions. During periods of uncertain market conditions, the Fund seeks to preserve capital. The Equity Fund will attempt to realize its investment objective primarily through investments in equity securities of U.S. companies, mutual funds and exchange-traded funds. The Equity Fund may also invest in foreign equity securities, U.S. and foreign debt securities and other investment instruments. The Equity Fund may also invest in other private investment funds. The DIF Fund’s investment objective is maximum capital growth and income during periods of favorable market conditions. During periods of uncertain market conditions, the Income Fund seeks to preserve capital. The Income Fund will attempt to realize its investment objective primarily through investments in fixed income securities issued by U.S. companies. The Income Fund may also invest in U.S. equity securities, foreign debt securities and other investment instruments. CP, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to either Fund. The terms and conditions for participation in the affiliated funds, including management and incentive fees, conflicts of interest, and risk factors, are set forth in each Fund’s offering documents. CP’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). In providing advisory services to the private funds, CP directs and manages the investment and reinvestment of the private fund's assets and provides reports to investors (through the private funds' administrator). CP manages the assets of each private fund in accordance with the terms of its governing documents. Each prospective client that elects to invest in the private funds will be required to complete a Subscription Agreement, pursuant to which the client shall establish that the client is qualified to invest in the private fund, and acknowledges and accepts the various risk factors that are associated with such an investment. CP clients who are invested in DEF or DIF are charged a 0.65% annualized expense ratio. CP adjusts the overall advisory fee by reducing the fee charged to assets under management in relation to the fee associated with fund management. This fee reduction serves to maintain the client’s blended fee at a level equivalent to their standard fee schedule. The recommendation that a client become an investor in an affiliated private fund could present a conflict of interest. No client is under any obligation to become an investor in any CP-sponsored fund. CP's Chief Compliance Officer, James Hagedorn, remains available to address any questions regarding this potential conflict of interest. Sub-Adviser to Private Fund: CP serves as a sub-adviser to CP Special Assets Fund LP. The primary Manager and general partner to CP Special Assets Fund LP is First Trust Capital Management L.P. The objective of this fund is to deliver private investments to clients of CP who are qualified purchasers at lower minimums than the minimum investment levels associated with the private funds within the underlying portfolio. Clients who invest in the fund have the ability to select which private funds to hold in their portfolio through the primary fund’s series LLC structure. The CP Special Assets Fund’s investment program seeks to achieve capital appreciation by investing in various hedge funds, private equity funds, growth equity funds, venture capital funds, credit funds, oil and gas funds, real estate funds, co-investment vehicles, managed accounts or other types of investment vehicles (collectively, the “Underlying Funds”), each of which is typically managed by a third party investment advisor (including CP, as the Sub- Advisor, if authorized by the Manager) or by the Manager or an affiliate of the Manager. CP, as sub-adviser, provides discretionary asset management to certain classes of the CP Special Assets Fund LP and CP may allocate client assets on a non-discretionary basis to sub-classes of the CP Special Assets Fund LP. No performance or incentive related compensation is payable to CP or any of its affiliates. Clients who invest in CP Special Assets Fund LP receive a monthly statement from an independent fund administrator and a certified annual financial statement prepared by a PCAOB auditor. The terms and conditions for participation in the CP Special Assets Fund LP are set forth in CP Special Assets Fund LP’s offering documents, which will be presented to each prospective fund investor. CP, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to CP Special Assets Fund LP . CP’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Each prospective client that elects to invest in this private fund will be required to complete a Subscription Agreement, pursuant to which the client shall establish that the client is qualified to invest in the private fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Conflict Of Interest. Because CP can earn compensation from the Fund (i.e., sub-management fees, incentive compensation, etc.) that could generally exceed the fee that CP would earn under its standard asset-based fee schedule referenced in Item 5 below, the recommendation that a client become a Fund investor presents a conflict of interest. No client is under any obligation to become a Fund investor. Given the conflict of interest, CP advises that clients consider seeking advice from independent professionals (i.e., attorney, accountant, adviser, etc.) of their choosing prior to becoming a Fund investor. B.8. Miscellaneous Limitations of Financial Planning and Consulting/Implementation Services. As indicated above, to the extent requested by the client, CP may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. CP will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, stand-alone planning engagements, etc. for which Firm may charge a separate or additional fee). Please Note. CP believes that it is important for the client to address financial planning issues on an ongoing basis. CP’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with CP. CP does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Neither CP nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. Accordingly, CP does not prepare estate planning documents or tax returns. In addition, CP does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with CP, if desired. To the extent requested by a client, CP may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.), including representatives

of CP in their separate individual capacities as licensed insurance agents or attorneys. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from CP and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not CP, shall be responsible for the quality and competency of the services provided. Conflict of Interest: The recommendation by a CP representative that a client engage the services of a CP representative in his/her separate and individual capacity as an insurance agent or attorney, presents a conflict of interest, as the receipt of compensation for such services may provide an incentive to recommend such services based on compensation to be received, rather than on a particular client’s need. No client is under any obligation to utilize the services of such affiliated professionals. Clients are reminded that they may implement CP’s recommendations through other, non-affiliated professionals. CP’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Please Note: Fee Differentials. As indicated below at Item 5, if a client determines to engage CP to provide discretionary or non-discretionary investment advisory services on a fee-only basis, CP’s annual investment advisory fee, generally ranges between 0.35% and 1.25%, based upon various objective and subjective factors. As a result, our clients could pay diverse fees based upon the market value of their assets, the complexity of the engagement, the level and scope of the overall investment advisory services to be rendered, and client negotiations. (See also Fee Differential discussion above). As a result of these factors, similarly situated clients could pay diverse fees, and the services to be provided by CP to any particular client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly. Before engaging CP to provide investment advisory services, clients are required to enter into a discretionary or non-discretionary Investment Advisory Agreement, setting forth the terms and conditions of the engagement (including termination), which describes the fees and services to be provided. ANY QUESTIONS: CP’s Chief Compliance Officer, James Hagedorn, remains available to address any questions regarding Fee Differentials. Schwab Advisor Network®. CP receives client referrals from Charles Schwab & Co., Inc. through its participation in the Schwab Advisor Network®. CP’s participation may raise potential conflicts of interest described below. See disclosure at Items 12 and 14 below. Retirement Rollovers-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 CP recommends that a client roll over their retirement plan assets into an account to be managed by CP, such a recommendation creates a conflict of interest if CP will earn new (or increase its current) compensation as a result of the rollover. If CP provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), CP is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by CP, whether it is from an employer’s plan or an existing IRA. Trustee Services. CP, through its supervised persons, offers trust services, where a member of CP shall serve as trustee to its clients. CP also serves as the investment manager to the trust assets where such trust assets have been referred to CP, or one of its supervised persons, for trust administration services. Thus, CP remains responsible for asset management decisions regarding trust assets. There is no additional fee charged to the investment management client for this service. CP supervised persons serving as trustee for the client shall act in accordance with the terms and conditions of the applicable trust documentation. Unaffiliated Private Investment Funds. In limited situations, CP may provide investment advice regarding unaffiliated private investment funds. CP’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of CP calculating its investment advisory fee. CP’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation. In the event that CP references private investment funds owned by the client on any supplemental account reports prepared by CP, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. The current value of any private investment fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report. Independent Managers. CP may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to-day responsibility for the active discretionary management of the allocated assets. CP will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. The CP generally considers the following factors when recommending Independent Manager(s): the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s) are exclusive of, and in addition to, CP’s ongoing investment advisory fee, which will be disclosed to the client before entering into the Independent Manager engagement and/or subject to the terms and conditions of a separate agreement between the client and the Independent Manager(s). Margin Accounts: Risks/Conflict of Interest. CP does not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. The broker charges the investor interest for the right to borrow money and uses the securities as collateral. Should a client determine to use margin, CP will include the entire market value of the margined assets when computing its advisory fee. Accordingly, CP’s fee shall be based upon a higher margined account value, resulting in CP earning a correspondingly higher advisory fee. As a result, the potential of conflict of interest arises since CP may have an economic disincentive to recommend that the client terminate the use of margin. ANY QUESTIONS: Our Chief Compliance Officer, James Hagedorn, remains available to address any questions that a client or prospective client may have regarding the use of margin. Use of Mutual Funds and Exchange Traded Funds: While CP may allocate investment assets to mutual funds and exchange traded funds (“ETFs”) that are not available directly to the public, CP may also allocate investment assets to publicly-available mutual funds and ETFs that the client could purchase without engaging CP as an investment adviser. However, if a client or prospective client determines to purchase publicly-available mutual funds without engaging CP as an investment adviser, the client or prospective client would not receive the benefit of CP’s initial and ongoing investment advisory services with respect to management of that asset. Other mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”), are generally only available through selected registered investment advisers. CP may allocate client investment assets to DFA mutual funds. Therefore, upon the termination of CP’s services to a client, restrictions regarding transferability and/or additional purchases of, or reallocation among DFA funds will apply. Cybersecurity Risk. The information technology systems and networks that CP and its third-party service providers use to provide services to CP’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in CP’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and CP are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although CP has established its processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that CP does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Structured Notes. CP may purchase Structured Notes for client accounts. A Structured Note is a financial instrument that combines two elements, a debt security and exposure to an underlying asset or assets. It is essentially a note, carrying counter party risk of the issuer. However, the return on the note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or commodities). It is this latter feature that makes structured products unique, as the payout can be used to provide some degree of principal protection, leveraged returns (but usually with some cap on the maximum return), and be tailored to a specific market or economic view. Structured Notes will generally be subject to liquidity constraints, such that the sale thereof before maturity will be limited, and any sale before the maturity date could result in a substantial loss. There can be no assurance that the Structured Notes investment will be profitable, equal any historical performance level(s), or prove successful. Please Note: If the issuer of the Structured Note defaults, the entire value of the investment could be lost. See additional Risk Disclosure at Item 8 below. In the event that a client has any questions regarding the purchase of Structured Notes for their account, or would like to place restrictions on the purchase of Structured Notes for their accounts, CP can address their concerns. Interval Funds/Risks and Limitations: Where appropriate, CP may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct CP, in writing, not to employ any or all such strategies for the client’s account. Portfolio Activity. CP has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, CP will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when CP determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by CP will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, CP shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless CP reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Cash Positions. CP continues to treat cash as an asset class. As such, unless determined to the contrary by CP, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating CP’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), CP may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, CP’s advisory fee could exceed the interest paid by the client’s money market fund. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, CP generally recommends that Schwab or Fidelity serve as the broker-dealer/custodian for client investment management assets. Broker- dealers such as Schwab and Fidelity charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab and Fidelity, do not currently charge fees on individual equity transactions, others do). Please Note: there can be no assurance that Schwab and/or Fidelity will not change their transaction fee pricing in the future. Please Also Note: Fidelity and Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. These fees/charges are in addition to CP’s investment advisory fee at Item 5 below. CP does not receive any portion of these fees/charges. ANY QUESTIONS: CP’s Chief Compliance Officer, James Hagedorn, remains available to address any questions that a client or prospective client may have regarding the above. Non-Discretionary Service Limitations. Clients that determine to engage CP on a non-discretionary investment advisory basis must be willing to accept that CP cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Therefore, in the event that CP would like to make a transaction(s) for a client's account (including in the event of an individual holding or general market correction), and the client is unavailable, CP will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Account Aggregation Services. In conjunction with the services provided by ByAllAccounts, Inc., eMoney Advisor (“eMoney”) and or Orion Advisor Services (“Orion”), CP may provide its clients with access to an online platforms hosted by third-party vendors. These platforms allow a client to view their complete asset allocation, including those assets that CP does not manage (the “Excluded Assets”). CP does not provide investment management, monitoring, or implementation services for the Excluded Assets. Additionally, the eMoney platform also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by CP. The client and/or their other advisors that maintain trading authority, and not CP, shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, CP shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that CP provides investment management services with respect to the Excluded Assets, the client may engage CP to do so pursuant to the terms and conditions of the Investment Advisory Agreement between CP and the client. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG”). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by CP), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Client Obligations. In performing our services, CP shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify us if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services. Disclosure Statement. A copy of CP’s written Brochure as set forth on Part 2A of Form ADV, along with our Form CRS (Relationship Summary), shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. C. CP’s Investment Philosophy The firm shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, CP shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the firm’s services. D. Wrap Fee Programs CP does not participate in wrap fee programs. (Wrap fee programs offer services for one all- inclusive fee.) E. Client Assets Under Management As of December 31, 2023, CP managed approximately $4,592,823,456 assets under management. $4,183,068,680 of that total is managed on a discretionary basis and $409,754,776 is managed on a non-discretionary basis.