A. Withum Wealth Management is a limited liability company formed on May 23, 2011 in the state of New Jersey. Withum Wealth Management became an SEC registered investment advisor firm on August 12, 2011. Withum Wealth Management is principally owned by Pinnacle Capital Management, LLC and WS&B Financial Services Group LLC. James F. Ferrare is Withum Wealth Management’s Managing Member. B. INVESTMENT ADVISORY SERVICES Withum Wealth Management provides discretionary investment advisory services on a fee-only basis. Withum Wealth Management’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Withum Wealth Management’s management, generally between 0.50% and 1.25%. Withum Wealth Management’s investment management services typically include: o A Dedicated Advisory Team o Customized Portfolio Design and Discretionary Management o Goals based approach with tax optimization overlay INTEGRATED WEALTH MANAGEMENT PLATFORM Withum Wealth Management offers its Integrated Wealth Management Platform (the “IWM Platform”) to those clients who have investment assets under management with Withum Wealth Management in excess of $2 Million. Participants in the IWM Platform are eligible to receive the following services in addition to the investment management services discussed above: • Wealth Planning o Retirement Planning o Unlimited Access to our team of Certified Financial Planner (CFP®) Professionals for Ongoing Wealth Advice • Annual Tax Preparation o Annual Personal Tax-Return1 • Periodic Estate Plan Review o Consultation with related Trust and Estate professionals o Review of strategies to minimize estate taxes and discussion of proper management of gifting and distributions If the client utilizes the professional tax preparation services of WS + B, CPA, and a dispute arises thereafter relative to the performance of such services, the client agrees to seek recourse exclusively from and against WS + B, CPA. The client retains absolute discretion over the selection and utilization of any professional service and as such is free to decline the tax preparation services offered under the IWM Platform. 1 Tax returns for IWM Platform participants will be prepared by WithumSmith + Brown, P.C. a certified public accounting firm (“WS+B, CPA”). (See Item 10 below) Conflict of Interest: The recommendation that a client engage WS + B, CPA in its capacity as a certified public accounting firm presents a conflict of interest, as Withum Wealth Management is affiliated with WS + B, CPA and it will derive an economic benefit from such engagement. RETIREMENT CONSULTING Withum Wealth Management also provides pension consulting services, pursuant to which it assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, Withum Wealth Management may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between Withum Wealth Management and the plan sponsor. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) Withum Wealth Management may be engaged to provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Prior to engaging Withum Wealth Management to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Withum Wealth Management 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 prior to Withum Wealth Management commencing services. If requested by the client, Withum Wealth Management may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professionals. 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 (i.e., attorney, accountant, insurance agent, etc.), and not Withum Wealth Management, shall be responsible for the quality and competency of the services provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Withum Wealth Management. It remains the client’s responsibility to promptly notify Withum Wealth Management if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Withum Wealth Management’s previous recommendations and/or services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Withum Wealth Management may provide financial planning and related consulting services. Neither Withum Wealth Management nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. Withum Wealth Management does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Withum Wealth Management, if desired. Withum Wealth Management will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax planning, insurance, etc. Withum Wealth Management does not serve as an attorney, accountant or insurance agent, and no portion of our services should be construed as legal, accounting or insurance services. Accordingly, Withum Wealth Management does not prepare estate planning documents or tax returns, nor does it sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance, etc.), including certain affiliated entities-see disclosure at Item 10 below. 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 Withum Wealth Management 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 Withum Wealth Management, shall be responsible for the quality and competency of the services provided. Private Investment Funds. One of Withum Wealth Management’s Members, Pinnacle Associates Ltd. (“Pinnacle Associates”), currently serves as investment adviser and/or General Partner of certain investment limited partnerships (the “Partnerships). To the extent certain of Withum Wealth Management’s individual advisory clients qualify, they will be eligible to participate as limited partners of the Partnerships. All relevant information, terms and conditions relative to the Partnerships, including the compensation to be received by Pinnacle Associates as the General Partner, suitability, risk factors, and potential conflicts of interest, are set forth in the Confidential Private Offering Memorandum, Limited Partnership Agreement and Subscription Agreement, which each limited partner is required to receive and/or execute prior to being accepted as a limited partner of any of the Partnerships. Withum Wealth Management also provides investment advice regarding unaffiliated private investment funds. Withum Wealth Management, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in an unaffiliated private investment fund, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. Withum Wealth Management’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Withum Wealth Management calculating its investment advisory fee. Withum Wealth Management’s fee shall be in addition to the fund’s fees. Withum Wealth Management’s clients are under absolutely no obligation to consider or make an investment in any 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 Withum Wealth Management references private investment funds owned by the client on any supplemental account reports prepared by Withum Wealth Management, 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 provided by Withum Wealth Management. Sub-Advisory Arrangements. Withum Wealth Management may engage sub-advisors for the purpose of assisting Withum Wealth Management with the management of its client accounts. The sub-advisor(s) shall have discretionary authority for the day-to-day management of the assets that are allocated to it by Withum Wealth Management. The sub-advisor shall continue in such capacity until such arrangement is terminated or modified by Withum Wealth Management. Withum Wealth Management shall pay a portion of the investment advisory fee received for these allocated assets to the sub- advisor for its sub-advisory services. Conflict of Interest: Withum Wealth Management has a sub-advisory agreement with one of its Members, Pinnacle Associates Ltd. (See Item 10.C below.). Withum Wealth Management’s Chief Compliance Officer, Carmine D’Avino, remains available to address any questions concerning Withum Wealth Management’s sub-advisory arrangements. Retirement Rollovers-Potential for 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 Withum Wealth Management recommends that a client roll over their retirement plan assets into an account to be managed by Withum Wealth Management, such a recommendation creates a conflict of interest if Withum Wealth Management will earn new (or increase its current) compensation as a result of the rollover. If Withum Wealth Management 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), Withum Wealth Management 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 Withum Wealth Management, whether it is from an employer’s plan or an existing IRA. Administrative Support. Withum Wealth Management has entered into a contractual relationship with one of its Members, Pinnacle Associates Ltd. to assist Withum Wealth Management with administrative support services. Cash Positions. Withum Wealth Management continues to treat cash as an asset class. As such, unless determined to the contrary by Withum Wealth Management, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Withum Wealth Management’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), Withum Wealth Management 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, Withum Wealth Management’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Withum Wealth Management shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Withum Wealth Management 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, the size of the cash balance, 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. The above does not apply to the cash component maintained within a Withum Wealth Management actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Withum Wealth Management unmanaged accounts. Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by Withum Wealth Management independent of engaging Withum Wealth Management as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Withum Wealth Management’s initial and ongoing investment advisory services. Use of DFA Mutual Funds. Withum Wealth Management utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers. Therefore, if the client was to terminate Withum Wealth Management’s services, and not transition to another adviser who utilizes DFA funds, restrictions regarding additional purchases of, or reallocation among other, DFA funds will generally apply. Structured Notes. Withum Wealth Management 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. If the issuer of the Structured Note defaults, the entire value of the investment could be lost. Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and 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 limited 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 Withum Wealth Management), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Withum Wealth Management does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, Withum Wealth Management shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Independent Managers. Withum Wealth Management may allocate a portion of the client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets, including, to the extent applicable, proxy voting responsibility. Withum Wealth Management shall 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. Factors that Withum Wealth Management shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, Withum Wealth Management’s investment advisory fee disclosed at Item 5 below. Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin, Withum Wealth Management, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, Withum Wealth Management will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Withum Wealth Management does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Withum Wealth Management considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Interval Funds/Risks and Limitations. Where appropriate, Withum Wealth Management may utilize interval funds (and other types of securities that could pose additional risks, including lack of liquidity and restrictions on withdrawals). 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. Therefore, 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 Withum Wealth Management, in writing, not to purchase interval funds for the client’s account. eMoney Advisor Platform. Withum Wealth Management may provide its clients with access to an online platform hosted by “eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view their complete asset allocation, including those assets that Withum Wealth Management does not manage (the “Excluded Assets”). Withum Wealth Management does not provide investment management, monitoring, or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, Withum Wealth Management’s service relative to the Excluded Assets is limited to reporting only. Therefore, Withum Wealth Management shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, shall be exclusively responsible for such investment performance. Without limiting the above, Withum Wealth Management shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may choose to engage Withum Wealth Management to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Withum Wealth Management and the client. The eMoney platform also provides access to other types of information and applications including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by Withum Wealth Management. Finally, Withum Wealth Management shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without Withum Wealth Management’s assistance or oversight. Portfolio Activity. Withum Wealth Management has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Withum Wealth Management 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, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Withum Wealth Management determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Client Obligations. In performing its services, Withum Wealth Management 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 Withum Wealth Management if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Withum Wealth Management’s previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that Withum Wealth Management and its third-party service providers use to provide services to Withum Wealth Management’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Withum Wealth Management’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Withum Wealth Management 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 Withum Wealth Management has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Withum Wealth Management 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. Disclosure Statement. A copy of Withum Wealth Management’s written Brochure as set forth on Part 2A of Form ADV and its Client Relationship Summary as set forth in Form CRS shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. C. Withum Wealth Management 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, Withum Wealth Management 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 Withum Wealth Management’s services. D. Withum Wealth Management does not participate in a wrap fee program. E. As of December 31, 2023, Withum Wealth Management had $1,580,487,586 in assets under management on a discretionary basis.