Advisory Business Sapient has been providing advisory services since its formation in 2010 as Sapient Private Wealth Management, LLC and since 2011 as Sapient Private Wealth Management Services, LLC (“SPWM”). SPWM is managed by Greg Erwin and Dennis Konrady (“SPWM Principals”), pursuant to a management agreement between SPW Management, LLC and SPWM. The SPWM Principals serve as leaders and officers of SPWM and are responsible for the management, supervision and oversight of SPWM. FOCUS FINANCIAL PARTNERS SPWM is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, SPWM is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because SPWM is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of SPWM. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. As of December 31, 2023, SPWM had $1,201,349,499 in discretionary regulatory assets under management, as well as an additional $54,305,206 in non-discretionary regulatory assets under management. SPWM offers several types of services to our clients, including:
• Investment Management,
• Comprehensive Wealth Management,
• Personalized Cash Flow Management, and
• ERISA Section 3(38) Investment Manager Services Investment Management SPWM generally provides investment management services on a discretionary basis, although SPWM makes an effort to accommodate reasonable client requests for certain investment restrictions. SPWM begins by taking sufficient time and effort to understand its clients’ current lifestyle needs, risk tolerance and future aspirations. Next a clear statement of objectives is prepared to reflect liquidity and cash flow needs, tolerance for volatility and risk and the target return necessary to meet long-term goals. Ultimately a customized portfolio with asset allocation targets is created to provide guidelines for maintaining proper portfolio balance. We generally create a portfolio consisting of separately managed accounts, mutual funds, exchange traded funds and individual fixed income instruments such as certificates of deposit, U.S. Treasury securities and tax exempt municipal bonds. SPWM uses client-authorized third party service providers to perform certain services, as applicable, for a client’s account. We utilize Envestnet for trading and research and Orion Advisors (“Orion”) for performance reporting and billing. Clients may directly access their accounts through the Orion portal. We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). Comprehensive Wealth Management Along with customized investment planning and implementation, we offer comprehensive wealth management services to produce a fully integrated approach to preserving, enhancing and transferring wealth. SPWM’s wealth management services are tailored to the individual client and include liquidity and cash flow management, risk management, tax management, financial planning, philanthropic planning, estate planning, and education planning. Service What We Provide Liquidity and Cash Flow Management Goal:
• We work closely with clients to develop budgetary guidelines designed to provide proper levels Meet income and emergency cash needs of cash and liquid investments are maintained
• We regularly review and rebalance client portfolios to meet current income needs, and to provide liquidity for emergencies and opportunities Risk Management Goal: Mitigate investment risk by striving for lower portfolio volatility
• A strong emphasis on establishing relevant risk controls for each client
• By diversifying investments among a range of asset classes, we aim to reduce portfolio volatility and improve overall performance
• Careful consideration to reduce exposure to interest rate, credit, business, and inflation risks, among others Tax Management Goal: Minimize impact of taxation
• Our advisors review portfolios for opportunities

to minimize tax exposure
• Collaborate with clients’ tax advisors to coordinate and implement tax efficient strategies Philanthropic Planning Goal: Maximize tax benefits of charitable giving
• Helping clients find solutions for charitable giving to support their preferred organizations
• Collaborate with clients’ tax and legal advisors on strategies to maximize the tax benefits of charitable giving Estate Planning Goal: Actualize desired dispensation of assets to beneficiaries
• Legacy counseling to discuss wealth transfer challenges and to provide for the smooth, tax- efficient transfer of wealth
• Close coordination with estate and tax planning professionals
• Succession strategies for the continuity of a family business Education Planning Goal: Prepare for the education of heirs
• To prepare for the education for heirs, we assist with assessing the costs
• We help plan investments designed to meet both growth and liquidity needs to cover educational expenses for the next generation Cash Flow Management Services We provide access to personalized cash management services and on-line services to help with financial decisions and daily banking activities. Additionally, our concierge service provides knowledgeable advice regarding loan procurement processes, including assistance with locating favorable interest rates, obtaining necessary forms, and other financial-related guidance. ERISA Section 3(38) Investment Manager Services SPWM provides investment management services on a discretionary basis to pooled and participant-directed 401(k) plans. In this capacity, SPWM is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. SPWM is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, SPWM is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). Fiduciary advisory services we provide to 401(k) plans include discretionary authority to select, monitor, remove, and replace the investment alternatives available to Plan trustees and participants under the terms of the Plan. SPWM does not provide fiduciary investment advisory services to participants at a participant level, only at the Trustee level. However, SPWM provides investment education to participants so they may choose an allocation strategy or construct a portfolio from the available mutual funds or models that meets their needs, objectives, time horizon, and risk tolerance. As a fiduciary, SPWM has duties of care and loyalty to its clients and is subject to obligations imposed on it by the federal and state securities laws. As a result, clients have certain rights which cannot be waived or limited by contract. Nothing in SPWM’s agreement with the client should be interpreted as a limitation of its obligations under the federal and state securities laws or as a waiver of any unwaivable rights client possess. Use of Separately Managed Accounts As applicable, our clients authorize us to enter into agreements with Separate Account Managers for services in connection with the management of the clients’ accounts on the terms and manner that our firm deems appropriate. In certain situations, a client may be required to engage the Separate Account Managers in a separate written agreement between the client and the designated Separate Account Managers, which include separate fees in addition to our management fee. Our firm is authorized to add, terminate, or change Separate Account Managers when, in our sole discretion, we believe such action is in the best interest of clients and their objectives. However, when clients choose to retain securities, funds, or Separate Account Managers no longer on our approved list, SPWM will conduct limited monitoring of the holdings and will continue to charge fees based upon assets within those client portfolios. A client may come to SPWM with legacy assets which are not part of the Firm’s strategy and consequently are not on our approved securities list. SPWM will work with such clients to plan to sell such legacy positions as feasible in order to align the client’s investment portfolio over time with SPWM’s recommended holdings. There may be tax, client preference, or other considerations impacting the timing of such disposition of legacy positions. Clients should understand since their legacy assets were not initially recommended by SPWM or are not on our approved list, our Firm has not necessarily performed, and does not perform, due diligence on these securities, managers, or positions. Legacy positions which are designated as non- managed assets excluded from the value of a client’s account for billing purposes shall be so designated in a client’s investment advisory agreement together with any amendments and addenda thereto. Our fee-only structure means we are compensated solely through client fees for our services, as either a percentage of assets under management or in some cases as fixed fees. This method removes some of the conflicts inherent when compensation