BACKGROUND INFORMATION Columbia River Advisors is registered with the Securities and Exchange Commission (the “SEC”) as a Registered Investment Adviser, under the Investment Advisors Act of 1940, as amended (the “Advisors Act”), with its principal place of business located in Tacoma, Washington. CRA also has branch offices located in Bellevue, Washington and Burien, Washington. CRA commenced business by filing with the State of Delaware limited liability company and then registered with the Washington Secretary of State to conduct business in November 2011. As of the date of this delivery- the principal owners of CRA and their respective ownership interests are as follows: Ben Addink: 31.67% Matt Keefe: 31.67% Brian Scalabrine: 31.66% Dave Pruitte: 5% CRA’s primary advisor business is to manage the investment portfolios of individuals and businesses (the “clients”) through its investment adviser representatives (the “IAR” or “IARs”), who provide investment advice based on the individual needs of the clients. The IARs will discuss a Client’s particular financial situation and will help them to establish and document their financial goals, investment objectives, time horizons, and level of investment risk tolerance. The Advisor Representatives also review and discuss a Client’s prior investment experience to properly advise and ensure that the advisory services provided are appropriate, which is then documented in the Portfolio Management Agreement (the “Portfolio Management Agreement” or “PMA”) executed between a Client and CRA for these services. In this capacity, CRA and its IARs act as fiduciaries for clients. PORTFOLIO MANAGEMENT OVERVIEW CRA’s Advisor Representatives serve as portfolio managers to CRA clients and manage their accounts with various investment methodologies that are disclosed under Item 8, Investment Strategies, below. Securities used by CRA include but are not limited to the following: (a) Mutual Funds (open-ended), no-load or load waived; (b) Exchange Traded Funds; (c) Equity and fixed income securities (individual equities, corporate debt, certificates of deposit, municipal securities, and US government securities); and (d) Alternative assets, which may include, liquid mutual funds, liquid exchange traded funds, and private placements (not liquid “Funds or Fund”). Services are provided on primarily a discretionary basis (transactions are placed on your behalf without prior knowledge, consistent with your objectives and needs) or on a non-discretionary basis (where you are required to confirm, prior to our placement, each transaction for your account(s)). Our non-discretionary clients are “legacy clients” from firms acquired by CRA that have kept their non-discretionary status. IDENTIFYING CLIENT’S GOALS AND OBJECTIVES For CRA to better understand a Client’s investment objectives and level of risk tolerance, CRA may utilize several techniques, including but not limited to, the following: �� Investment Policy Statements (“IPS”). These statements are used by CRA to document each Client’s goals, objectives, risk tolerances, personal and family obligations, and related data points. This allows for the appropriate portfolio construction and asset allocation. A certain number of our clients, that have been obtained through acquisition of investment advisory books of business (the “Books of Business”), have had an IPS prepared and updated prior to CRA’s acquisition of that firm. It is this IPS that CRA reviews with each Client and we work with you to keep the IPS updated. Typically, this is annually or when a Client’s personal or financial situation changes. This IPS is reviewed with the Client during a portfolio management review by the Advisor Representative and any changes are updated in the IPS. The IPS is often referred to as our Client Information Sheet. MARGIN ACCOUNTS Clients often open cash accounts (accounts valued with security holdings, and cash). To eliminate an opportunity for a trade error in an account where the client has used available cash with a debit card or check on the account, a client can request or inquire about a margin account. CRA may also suggest the client open a margin versus a cash account. In a margin account, the securities and account value are used as collateral from your broker / custodian that creates additional value in your account based on the total account value. This margin loan balance is up to 50% of the total account value before the margin. For example, an account value of $500,000 creates margin available of $250,000. There is no requirement for CRA or a client to use a margin value, however, if used, you, the client will pay margin interest fees to your broker / custodian for ANY margin value used. We have found this is very convenient for clients, especially if unknown expenses are created (home, car, family member, medical event, etc.). A margin account is only used when requested by a client. Not all our clients have margin accounts. They are created in the account application form with your broker / custodian, including additional documentation and disclosures from your broker / custodian. We are happy to address any questions you may have on margin and margin accounts. CRA’S MODEL PORTFOLIOS AND INVESTMENT PROCESS CRA uses investments in customized asset allocations comprised of traditional asset classes which can include: Equity, Fixed Income, and Alternative Asset Classes including Cash. Security types used for all asset classes include: Mutual funds, exchange traded funds (“ETFs”), active/passive Smart Beta Strategies and passive ETFs, across all of the CRA designed Model portfolios (the “Model Portfolios or Models”). These Models are created with varying investment return expectations and associated risks. These Models are designed to provide both passive and active investment management through these described asset classes. Certain asset class Mutual Funds and ETFs are also considered liquid tactical alternative assets, for example, real estate, commodities, etc. CRA’s Model Portfolios include the following and each is structured with between zero and four percent (0%-4%) cash allocation: *Conservative *Moderate *Balanced *Growth *Equity Growth *Tax Managed Conservative *Tax Managed Moderate *Tax Managed Growth *Tax Managed Equity Growth Not all IARs use CRA’s standard corporate investment models. Some models are legacy models and were created by and are managed by your specific IAR. Not all IARs are supervised or monitored by CRA’s investment committee or Managing Member (Matt Keefe). INVESTMENT RESTRICTIONS OR LIMITATIONS Investment restrictions or limitations you may impose on us, if any, are documented in the Portfolio Management Agreement that a client has signed with CRA. Changes to investment restrictions that you request are reviewed by CRA and approved in writing, and/or noted in CRA’s CRM system in the Client’s file. However, CRA reserves the right not to accept an account (or to terminate an account) if we believe the investment restrictions are so restrictive that we cannot deliver our portfolio management services to you and meet our contractual, fiduciary obligations. Investment restrictions include, but are not limited to the following: �� Equity Concentrations. For example, if a Client works for a company that issues stock, the restriction would be the Client cannot accumulate any more of that particular security through their engagement with CRA. �� Restrictions for Moral Reasons. For example, tobacco, foreign issuers, child labor, violations of federal and state securities regulations, weapon manufacturers, etc. �� Unmanaged Assets. Those assets held in your account for your convenience, but not “managed” by CRA are unmanaged (the “Unmanaged Assets”). Unmanaged Assets are not included in total account values for fee calculations or performance calculations under the terms of your PMA; they are listed (whether manually input by us or held by the broker / custodian for your account, either at Fidelity, or Schwab, see Item 12 below) as a convenience for clients. Our back-office service provider, Orion Advisor Services (“Orion”) uses the term “unsupervised” with the same meaning as Unmanaged Assets. SUB-ADVISORY SERVICES AND OTHER INVESTMENT ADVISORS From time to time, CRA may recommend that our clients use the services of a third-party money manager ("TPMM") to manage all, or a portion of, their investment portfolio. After gathering information about our clients’ financial situation and objectives, we may recommend that our clients engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, our clients’ financial needs, investment goals, risk tolerance, and investment objectives. We will review the TPMM's performance to ensure its management and investment style are consistent with our clients’ investment goals and objectives. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate our clients’ assets to other TPMM(s) where we deem such action appropriate. CRA would maintain the responsibility to determine whether the model is appropriate for our client. Once we pick the model for our client, the platform will automatically process the transaction. A TPMM does not verify any information they receive from us or our agent(s) for accuracy. It is our responsibility to promptly update our client's account application with any changes that our clients disclose to us regarding their financial situation or investment objectives. PRIVATE FUNDS1 These are alternative investments (the “Alternative Investments or Fund(s)” and generally are available only to those of our clients who qualify as an Accredited Investor, as defined under Regulation D, Section 501 of the Securities Act of 1933 (the “33 Act”) or other regulatory net worth qualifications. We will only recommend a Fund when the recommendation is suitable for you, based on your previously identified investment objectives and level of risk tolerance. Alternative Investments have a higher degree of risk, are not generally traded on public markets and are not easily convertible into cash. Alternative Investments are included in a Client’s overall portfolio management fee calculation and will typically have the security value at the most recent net asset value (the “NAV”) prepared by a third-party administrator or another vendor of the issuer of the security. 1Columbia River is the General Partner and investment adviser to Blue Water Investment Fund II, L P. HOUSEHOLDING OF ACCOUNTS2 When determining your investment goals and objectives, we will group your accounts by household (the “Household Account (s)”), which are generally accounts that have the same physical address. This allows us to better understand your full financial picture, including a risk tolerance survey that applies to your assets under our management as one group or “household.” Each Household Account is identified in the Portfolio Management Agreement, executed with CRA and includes, but is not limited to the following: (a) individual; (b) joint (husband, wife, brother/sister, or parent); (c) uniform gift to minor accounts (“UGMA”); for children); (d) individual retirement accounts (“IRAs”) or Roth IRAs; and (e) trusts or estates, among others, if they meet the criteria. Some types of accounts cannot be classified as Household Accounts, including, but not limited to, a corporation’s capital reserve or certain “qualified plans”, such as the Employee Retirement Income Security Act (“ERISA”). These types of accounts can have their own: (a) Portfolio Management Agreement; (b) risk tolerance analysis; and (c) separate quarterly reports. FINANCIAL PLANNING/CONSULTING CRA believes financial planning is an important component in providing services to our clients. For new client relationships, CRA will review a Client’s investment and other assets to prepare a summary of your assets which will help us identify and monitor your investments. Additionally, CRA also has IARs who can provide more extensively researched financial planning services. Based on your specific needs and questions, this may be in the form of a limited financial assessment of Client needs (the “Limited Financial Plan”) or a more formal written comprehensive financial plan (the “Comprehensive Financial

Plan”), both are further described below. Clients who enter into a Portfolio Management Agreement with CRA have access to CRA IARs and can receive a Limited or Comprehensive Financial Plan for no additional fee. For those individuals who do not enter into a Portfolio Management Agreement with CRA, they can elect to have a Limited Financial Plan, or a Comprehensive Financial Plan prepared by entering into a financial planning agreement (the “Financial Plan Agreement”), where a financial planning fee would be charged. See Item 5 for more details. LIMITED FINANCIAL PLAN The Limited Financial Plan is designed to provide a more basic understanding of a Client’s current financial situation, as compared to where they would like to be in the future. The Limited Financial Plan is less formal and provides less detail than the Comprehensive Financial Plan. The Limited Financial Plan is more topical and limited in scope, such as being focused on only one question or issue and is provided in the form of a discussion, summary letter, or other communication to a client, resulting from and assessment of a client’s question or issue related to their financial assets. COMPREHENSIVE FINANCIAL PLAN Generally, our Comprehensive Financial Plan encompasses several areas that affect your personal life and financial assets. These areas include, but are not limited to the following:  Wealth accumulation and preservation: retirement, setting goals, IRA rollovers, 401k rollovers, tax management, multi-generational IRAs, and charitable donations.  Realistic lifestyle management: education savings.  Tax consequences and solutions.  Personal portfolio tailoring: investments, retirement, estate planning, and management of probate expenses, management of estate taxes, family asset management, property titles, post death, and other tax advice.  Insurance – Risk Management: current and future risk exposures, in place coverage for cost effectiveness, long term care and independence, and family income in the event of disability or death. To develop a Comprehensive Financial Plan, we will work closely with you and your other professional service providers, such as attorneys, accountants, other advisors, etc. The Comprehensive Financial Plan provides a detailed analysis and is not limited to any product or service to help identify and address your specific financial planning needs. The plan will cover your personal financial goals, objectives, taxes, retirement, trusts, and other financial obligations, among others. We may assist you in the implementation of the recommendations that are set forth in the Comprehensive Financial Plan; however, that is solely your decision. Our financial planning recommendations are broad in scope and are not limited to any product or service to help identify and address your specific financial planning needs. The output of a Comprehensive Financial Plan includes but is not limited to the following: (a) recommended changes, to assist you in meeting your goals or objectives; (b) changes in your overall asset allocation; (c) changes to your saving habits; (d) realistic goals to achieve your retirement expectations; (e) establish trusts or estate documents (tax planning); and (f) other recommended needs. INSURANCE PRODUCT SERVICES CRA may have IARs or employees who are insurance agents licensed to sell insurance products or services to individuals. CRA clients are not obligated to use these insurance agents for insurance services and may use any insurance agency or 2 Householding of accounts for EAM clients that were acquired by CRA are grandfathered, therefore, some Householded accounts do not meet the criteria as described above, including one former IAR, Cottle, whose accounts were not “householded” prior to his joining CRA. As a result, these clients may pay higher advisory fees than if their accounts were householded as described in this Brochure. broker you choose to implement financial or estate planning recommendations. When recommendations are made for the purchase, sale, or exchange of insurance products, a disclosure of the conflict must be provided to the client. CRA prohibits the recommendation, purchase, sale, or exchange of insurance services or products for clients subject to the Employment Retirement Income Security Act (“ERISA”) or the Internal Revenue Code such as an Individual Retirement Account (“IRA”) or similar accounts under the Internal Revenue Code. 401K AND RETIREMENT SERVICES CRA provides investment advice to 401k plans and similar accounts as a named fiduciary. Depending upon the form and organization of the retirement accounts (e.g., 401k, pension, profit-sharing plan, money purchase pension plan, IRA, SEP- IRA, etc.), collectively (the “Plan”), the services are determined with each retirement client. As part of these fiduciary investment advice services, CRA may also provide “non-advice services” such as employee training or education to plan participants for the employer who sponsors the 401k (or similar) plan. For these accounts subject to ERISA, we have various tools and educational materials that assist a participant or retirement account holder in the development and determination of an “asset allocation” that makes the most sense for the individual account client. The retirement services we offer include, but are not limited to the following: �� Retirement Services Consulting. CRA provides mutual fund evaluation and recommendation services to the retirement plan trustees and /or the account holder. When providing advice to a Plan, the Plan itself is our Client. The trustees (one or more employees of the company sponsoring the plan) are “named fiduciaries” to the plan under ERISA and enter into an agreement with CRA, which identifies the services provided. These are either 3 (21) or 3 (38) services by CRA to the Plan and its trustees, as identified under these sections of ERISA. �� Non-discretionary / consulting. For 3 (21) services, the plan’s named fiduciaries are charged with the final determination to accept or reject investment recommendations made by CRA. In addition, these named fiduciaries are responsible for the overall administration of the plan (and their various service providers, including a broker / custodian, plan administrator, etc.). Services of this nature are provided typically to “daily valued 401k plans”. Advice provided by the plan’s trustees and CRA is for the sole interest of the plan and its participants. �� Discretionary advisory services. For 3 (38) services under ERISA, CRA, applicable to a few 401k or money purchase pension plans, is a named fiduciary with investment discretionary authority provided by the trustees to CRA. This means that CRA is charged with the development, monitoring, and making changes to the investment options of the plan, including asset allocation models used by the plan and its participants. As stated above, the plan trustees have the responsibility to monitor and provide administration of the plan and its service providers. All services provided by the trustees of the plan and CRA are in the sole interest of the plan and its participants. IMPORTANT INFORMATION FOR RETIREMENT INVESTORS When we recommend that you rollover retirement assets or transfer existing retirement assets (such as a 401(k) or an IRA) to our management, we have a conflict of interest. This is because we will generally earn additional revenue when we manage more assets. In making the recommendation, however, we do so only after determining that the recommendation is in your best interest. Further, in making any recommendation to transfer or rollover retirement assets, we do so as a “fiduciary,” as that term is defined in ERISA or the Internal Revenue Code, or both. We also acknowledge we are a fiduciary under ERISA or the Internal Revenue Code with respect to our ongoing investment advisory recommendations and discretionary asset management services, as described in the portfolio management agreement we execute with you. To the extent we provide non-fiduciary services to you, those will be described in the portfolio management agreement. GENERAL PARTNER FOR AFFILIATED PRIVATE EQUITY FUND BLUE WATER INVESTMENT FUND II, L.P. CRA formed Blue Water Investment Fund II, L.P., (“BW II”), in May 2012 and is the GP (the “General Partner”). BW II’s primary investment strategy is to provide debt financing to CRA, which is also the general partner to BW II, who in turn combines the loan proceeds with seller-financing, if applicable, to acquire or refinance the acquisition of investment advisory “books of business” (the “Books of Business”). In return for the loan proceeds, the General Partner issues fixed rate and secured promissory notes (the “Promissory Notes”) to BW II, subject to priority loan positions. The loans bear an interest at a rate equal to the prime rate (at the time the promissory note is executed) plus five percent (5%) and pay no less frequently than semi-annual payments of the principal and accrued interest during the life of the loan that are amortized with a final balloon payment. The loans by BW II to the General Partner are collateralized by a second position priority lien in the Books of Business acquired by the General Partner (subordinated to any seller financing or commercial bank loans) and, collectively, a first position priority lien on all the General Partner’s other assets. As of the date of this filing, BW II has 1 Promissory Note issued from CRA. The Promissory Note pays an annual interest of 8.25%. Based on the prime rate plus 5% at the time of issuance. NO REDEMPTION PRIOR TO MATURITY DATE UNLESS APPROVED BY THE GENERAL PARTNER Under the terms of the BW II limited partnership agreement, a limited partner in BW II is not permitted to withdraw any part of their investment prior to the Maturity Date, unless approved by the General Partner. While the General Partner is not required to meet any BW II limited partner redemption requests prior to the Maturity Date, it may, at its sole discretion, attempt to allocate available net cash flow from operations and/or financing to those BW II limited partners that notify the General Partner of a redemption request prior to the Maturity Date. When the General Partner can allocate cash for the redeeming BW II, they will be proportionately allocating cash that the General Partner is paying out for redemption, based on their respective ownership percentage of BW II. PROMISSORY NOTES RISK OF LOSS As the BW II offering documents disclosed, an investment in BW II is highly speculative and an investor could lose all or a portion of their investment. Prior to the Maturity Date, the General Partner believes that its normal business operations and financial position will allow it to obtain financing from a commercial lender to pay off the Promissory Note. The General Partner requested extensions on the maturity of the Promissory Note from BW II investors and opened the fund up to possible new investors in 2020. If in the future the General Partner is not able to refinance or receive extensions for the current Promissory Note, the General Partner may be forced to liquidate all or a portion of its Books of Business, the collateral underlying the Promissory Note, to attempt to meet the Promissory Note contractual loan commitments. Furthermore, if the General Partner is forced to liquidate its Books of Business to pay off the Promissory Note, there is no guarantee that the proceeds from the sale of the Books of Business would be adequate to meet its loan commitments with BW II and the investors in BW II may lose all or a portion of their investment. AUDITED FINANCIALS REQUIREMENT FOR BW II CRA engaged Spicer Jeffries, LLP (“SJ”) to conduct the annual financial audit of BW II. BW II limited partners are provided with a copy of the audited financial report, prepared by SJ, in accordance with Generally Accepted Accounting Principles (“GAAP”). As required by the Advisors Act, these audited financials of BW II are required to be delivered to the BW II limited partners within one hundred twenty (120) days of BW II’s fiscal year end (12/31). If CRA learns that, in any given year, the audited financials prepared by SJ are going to be completed later than 120 days after the BW II fiscal year, CRA will inform all BW II limited partners in writing of the delay and provide an approximate time frame when the financial audit will be completed. CRA ASSETS UNDER MANAGEMENT AS OF DECEMBER 31ST 2023: Discretionary:3 $461,615,897.54 Non-discretionary:4 $10,247,442.85 Total Assets under Management: $471,863,340.39