As described more fully in Item 8 below, CFIA pursues primarily two investment advisory services/strategies: (1) investment management and advisory services to individuals, retirement plans, charitable foundations, private funds, mutual funds, and corporations. Our services are offered to clients through advisors and as a Turnkey Asset Management Program provider (collectively, “Clients”), and (2) a short-term notes strategy. Within the investment management and advisory services offering, the Firm offers a variety of model portfolios (usually as a Separately Managed Account). The first set of model portfolios consist of lower-cost, tax-efficient, and liquid exchange-traded funds (ETFs). The second set of model portfolios will consist of individual equity positions and possibly covered call options as well. In addition, CFIA manages four mutual funds: Cantor Fitzgerald Equity Dividend Plus Fund (new name effective 2/1/24, f/k/a Cantor FBP Equity & Dividend Plus Fund), Cantor Fitzgerald Infrastructure Fund, Cantor Fitzgerld Large Cap Focused Fund (new name effective 2/1/24, f/k/a Cantor Growth Equity Fund), and Cantor Fitzgerald International Equity Fund. The firm will also manage accounts as an adviser, sub adviser, and/or research provider to sponsored, all-inclusive asset-based fee programs or relationships. Within the short-term note strategy, CFIA provides advisory services to one or more financing vehicles (each a “Vehicles” and collectively the “Vehicles”). Cantor Fitzgerald Managed ETF Portfolios Investment management and advisory services, offered through Cantor Fitzgerald Investment Advisors (“CFIA”), are tailored to each Client’s stated objectives. At the beginning of the relationship, CFIA gathers information regarding a client’s overall investment objectives, risk tolerance and time horizon. Once an appropriate Portfolio has been selected for the Client, CFIA provides investment management through a three-step process:
• Asset Allocation
• Portfolio Construction
• Periodic Rebalancing ASSET ALLOCATION CFIA offers a variety of ETF Model Portfolios, and each Portfolio considers both a client’s risk tolerance and their stated time horizon for meeting their investment goals. PORTFOLIO CONSTRUCTION CFIA constructs proprietary ETF investment Portfolios using strategic, tactical, and opportunistic asset allocation techniques. CFIA’s investment philosophy emphasizes macroeconomic research in creating an active asset allocation strategy. This strategy is implemented through unique time and risk-based Portfolios.. CFIA primarily utilizes index-based ETFs, which are passive managed investments, in order to gain diversified exposure to a desired asset class or category. Asset Classes and Categories may include: ▪ Equities (Stocks) - Includes, but is not limited to, US or Foreign Large Cap, Mid Cap, Small Cap, Real Estate Investment Trusts (REITs), Sector, Industry, and Emerging, Frontier and Other Global Markets ▪ Fixed Income (Bonds) - Includes, but is not limited to, Investment Grade, High Yield, Preferred Stocks, Foreign or Domestic Government and Agency and Emerging, Frontier and Other Global Markets ▪ Alternative Investments (Absolute Return) - Includes, but is not limited to, Commodities, Precious Metals, Currencies, Timber, Agriculture, Managed Futures, YieldCo’s, Inflation Expectations, Energy Master Limited Partnerships (MLPs), Hedge Fund Replication, Crypto Currency, and Merger Arbitrage ▪ Money Market, Bank Deposits, or equivalents. Please refer to Item 8 for further information on our methods of analysis and investment strategies, including details on the specific risks associated with these strategies. REBALANCING A PORTFOLIO Rebalancing is the process of selling a portion of an investment in a particular asset class or security that has increased as a percentage of the overall Portfolio to a level beyond its intended or target allocation. Proceeds from rebalancing sales are used to buy additional positions in other asset classes or securities that have fallen below their intended target allocation. Client Portfolios are reviewed at least quarterly to determine if rebalancing is appropriate. Please refer to Item 13 for further information on account reviews performed by CFIA Cantor Fitzgerald Value and Income Strategies Cantor Fitzgerald Value and Income Strategies will focus its primary investment expertise on implementing a large capitalization value approach in achieving its clients’ investment objectives. However, it may offer advice on a range of securities, which include and are generally limited to the following:
• Publicly traded equity securities
• Corporate debt securities
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• Exchange-traded funds (ETFs)
• United States government securities
• Option contracts on securities As financial markets and products evolve, may invest in other instruments or securities, whether currently existing or developed in the future,

when consistent with client guidelines and objectives. Please refer to Item 8 for further information on its methods of analysis and investment strategies, including details on the specific risks associated with these strategies. CFIA generally has investment discretion. Clients may limit their discretion by prohibiting or limiting the purchase of securities or industry groups or by imposing other limitations and/or requests. SPONSORED PROGRAM SERVICES CFIA participates in sponsored programs as more fully described in Item 10. Generally, CFIA manages accounts in these programs consistent with all other accounts it manages independently with similar investment objectives, risk tolerances and time horizons. The firm receives a portion of the total fee from the sponsoring organization for its services.
Vehicles Investment advice is provided directly to Vehicle (subject, in the case of a Fund to the discretion and control of the General Partner or Board of Directors of the Fund), and not individually to Vehicles note holders. Advisory Services are provided to each Vehicle in accordance with the Vehicle’s organizational documents. Investment restrictions for a Fund or Vehicle, if any, generally are established in the organizational or offering documents of the Fund or Vehicle. Cantor Fitzgerald Infrastructure Fund Cantor Fitzgerald Infrastructure Fund is a continuously offered, closed-end interval fund registered under the Investment Company Act of 1940 (the “1940 Act”). The Fund’s investment objective is to maximize total return with an emphasis on current income while seeking investments that are aligned with certain United Nations Sustainable Development Goals (“SDGs”). The Fund pursues its investment objective by strategically investing in a portfolio of both private institutional infrastructure investment funds (“Private Investment Funds”) and public infrastructure securities. CFIA, the Adviser, has engaged Capital Innovations, LLC a registered investment adviser under the Advisers Act, as sub-adviser, to provide ongoing research, recommendations, and day-to-day portfolio management with respect to the Fund’s investment portfolio. Cantor Fitzgerald Large Cap Focused Fund Cantor Fitzgerald Large Cap Focused Fund a continuously offered, open-end fund registered under the Investment Company Act of 1940 (the “1940 Act”). The Cantor Growth Equity Fund’s investment objective is to seek long-term growth of capital. The Cantor Fitzgerald Large Cap Focused Fund seeks to invest in companies with improving returns that, over time, will be converted to higher growth rates, the Fund employs quantitative and qualitative methodologies as part of its fundamental analysis to invest in high-quality common stocks with undiscovered positive earnings potential. CFIA, the Adviser, has engaged Smith Group Asset Management, LLC a registered investment adviser under the Advisers Act, as sub-adviser, to provide ongoing research, recommendations, and day-to-day portfolio management with respect to the Fund’s investment portfolio. Gathering Client Information At the onset of the Client relationship, CFIA gathers investment objectives, risk tolerance and time horizon for the investment management and advisory services offered by its’ Managed ETF Portfolios and Value and Income Strategies. The information is used by CFIA to determine the appropriate asset allocation Portfolio for each Client. CFIA does not assume any responsibility for the accuracy of the information provided by Clients and is not obligated to verify any information received from the Client or from the Client’s other professionals (e.g., advisor, attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, Clients are responsible for promptly notifying CFIA in writing of any material changes to the Client’s financial situation, investment objectives, time horizon, or risk tolerance. Cantor Fitzgerald Managed ETF Model Portfolios to Third Parties CFIA provides services under written platform agreements to non-affiliated third parties advisors, wherein CFIA provides the third-party advisors with model Portfolios in different investment strategies for a fee. The third-party advisor may in turn, at its sole discretion, use the model Portfolios as investment strategies to invest the assets of the third-party advisor’s clients. CFIA does not receive any personal or investment guideline information pertaining to the third-party advisor’s clients and does not manage or have discretion over any third-party advisor client’s assets. When acting as a sub-adviser to another RIA or when Cantor Fitzgerald Model Portfolio is utilized through a TAMP platform, the RIA is responsible for gathering client information including, but not limited to, investment objectives and risk tolerance. As of December 31, 2023, CFIA had assets under advisement (TAMP) of approximately $350, 263,771. As of December 31, 2023, CFIA had discretionary assets under management of approximately $1,643,515,117.