Our Advisory Firm Telemus Capital, LLC (“TC”, “we” or “us”) (CRD #168794) is an investment adviser which succeeded to the advisory businesses of its predecessor advisers, Telemus Investment Management, LLC (SEC # 801-131580), Telemus Wealth Advisors, LLC (SEC # 801-64748), and Beacon Asset Management, LLC (SEC # 801-67441) as of August 1, 2013, thereafter continuing business under the name “Telemus Capital, LLC.” The predecessors’ advisory businesses were originally founded in 2005. The advisory services and management of TC remained the same; however, the successor application dated August 29, 2013, reflected new ownership by Focus Operating, LLC (“Focus Operating”). Effective October 1, 2017, TC completed the acquisition of the assets of, and combination with, Barrington Strategic Wealth Management Group LLC (“Barrington”) of Chicago Illinois. Barrington was an SEC registered investment adviser providing investment management and wealth advisory services to its clients nationwide. The combined organization will continue business under the name of “Telemus Capital, LLC.” TC will continue to maintain Barrington’s presence in Chicago, and the advisory services and management will remain the same. Focus Operating, LLC, Focus Financial Partners, LLC, and Focus Financial Partners Inc. TC is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, TC is a wholly owned subsidiary of Focus Operating, LLC (“Focus Operating”), which is a wholly owned subsidiary of Focus LLC. Focus Financial Partners Inc. (“Focus Inc.”) is the sole managing member of Focus LLC and is a public company traded on the NASDAQ Global Select Market. Focus Inc. owns approximately two-thirds of the economic interests in Focus LLC. Focus Inc. has no single 25% or greater shareholder. Focus Inc. is the managing member of Focus LLC and has 100% of its governance rights. Accordingly, all governance is through the voting rights and Board at Focus Inc. 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. TC is managed by Lyle Wolberg, Robert A. Stone, Joshua S. Levine and Ari Fischman (“TC Principals”), pursuant to a management agreement between TCP Management, LLC and TC. The TC Principals serve as leaders and officers of TC and are responsible for the management, supervision and oversight of TC. TC Clients We provide personalized and confidential wealth management services to clients, who are primarily high net worth individuals, trusts and family offices, sponsors of retirement plans, charitable organizations, municipal government entities and business entities. These services include investment management, financial planning and advising on estate planning and insurance needs. We and affiliated entities also manage private investment funds. Discretionary Investment Advisory Services Our investment management services are generally provided on a discretionary basis, though clients who invest in our affiliated private investment funds must affirmatively elect the investment on a non-discretionary basis. Our Advisory Role At the outset of each client relationship through an interactive process, TC evaluates each client’s financial circumstances, risk tolerance, investment objectives and goals. As part of the evaluation, clients may impose restrictions on investing in certain securities or types of securities. Based on the results of the client discussion(s) and the information provided by the client, we prepare a Financial Life Proposal for the client which includes the agreed upon investment strategy. For clients using the Envestnet program (described below), we prepare and review with the client a customized Statement of Investment Selection (“SIS”). The SIS incorporates an investment profile summary, summarizes the information the client has provided us and makes recommendations for the client’s portfolio based on the information provided. Using tools provided by Envestnet, we may recommend that the client’s portfolio be allocated among various investment managers and/or products. After reviewing the client’s final investment strategy or SIS (in the case of clients using the Envestnet program), the client enters into an investment advisory agreement (“Client Agreement”) with TC. The Client Agreement discusses the services to be provided to the client and other applicable terms and conditions. For most client accounts, TC constructs client portfolios generally in accordance with our traditional model strategies: Income Only, Capital Preservation, Conservative, Moderate, Balanced, Aggressive, Ultra Aggressive and Growth Only. Client portfolios are managed in accordance with the model strategy most appropriate for the client’s risk profile. Each model strategy can allocate across as many as five sleeves: Growth, Diversifier, Income (either with taxable or tax- exempt bonds), Private Investments and Cash. Allocations to each sleeve are made in differing percentages depending on the risk profile of each model. All of the model strategies include some combination of individual equities, individual bonds, mutual funds, ETFs, private funds and potentially other investment products. For accounts not deemed large enough for the traditional models or clients seeking a passively managed portfolio, including but not limited to in the Telemus Digital product, TC also constructs client portfolios in accordance with the following model strategies: Ultra-Conservative, Conservative, Moderate, Balanced, Aggressive and Ultra-Aggressive. Client portfolios are managed in accordance with the model strategy most suitable for the client’s risk profile. Each model strategy has three sleeves: Growth, Income and Cash. Allocations to each sleeve are made in differing percentages to each model strategy depending on the risk profile of the strategy. All of these model strategies are constructed with passive ETFs. Clients should know that their assets in each model strategy are likely to be managed in a manner similar to other clients having similar investment objectives and risk tolerance. The implementation of a model strategy may vary depending on a client’s preferences for separately managed accounts, current income, liquidity constrains, taxes or environmental/social/governance concerns. 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). TC is the investment manager to the Telemus Decorrelation Opportunity Fund, LP (the “TDOF Fund”), and its affiliate, Telemus Decorrelation Opportunity GP, LLC, is the General Partner of the Fund. The TDOF Fund, which is a fund of funds, is a multi-strategy, privately offered investment vehicle that invests in a diversified portfolio of investments that seeks to provide low and non-correlated returns relative to the broader equity and fixed income markets. The underlying investment strategies include, but are not limited to, insurance-linked securities, longevity-contingent assets, real estate credit, alternative lending, and other assets that generally have low or non-correlated returns with traditional financial markets. The TDOF Fund is closed to new investors and is in the process of being dissolved. TC’s affiliate, Telemus Life Science Real Estate Fund Manager, LLC, is the Manager of the Telemus Life Science Real Estate Fund, LLC (the “TLSRE Fund”). The TLSRE Fund is a privately offered investment vehicle that was created for the purpose of investing in IQHQ, Inc., a privately traded REIT formed to acquire, develop and redevelop real estate for life sciences tenants. TC also has relationships with external providers of investment management, research and due diligence services. One such service provider is Envestnet1, a registered investment adviser that provides an asset management platform and related technology, as well as operational and administrative support services. TC uses some of the services provided by Envestnet, including the Unified Managed Account Program (the “UMA program”) and the Separate Managed Accounts Program (the “SMA program”). Through the UMA program TC constructs a single client portfolio comprised of various investment vehicles, typically third-party managers. Through the SMA program TC will select third party managers which are appropriate to manage the client’s assets. In both programs, the client grants TC with discretion to make changes to the managers and/or investments if TC determines such a change is in the client’s best interest. Factors considered in making this determination include account size, risk tolerance, the opinion of each client, the investment philosophy of the third-party manager, and the client’s investment objectives. TC will have full discretionary authority to invest and reinvest client assets and retain third party asset managers who, in turn, have full discretionary authority to invest and reinvest client assets, subject to reasonable restrictions imposed by the client. TC also provides Asset Management Services to select clients. When doing so, TC uses the following equity and fixed income investment strategies in managing clients’ assets:
• Core Equity: Actively managed core equity strategy that focuses on large- cap companies with demonstrated consistent, above-average earnings growth and reasonable valuations. It is managed relative to the Russell 1000 and/or S&P 500 Indices as benchmarks. Evercore

Wealth Management LLC currently serves as sub-advisor for this strategy.
• Investment Grade Taxable Fixed Income: Actively managed intermediate taxable bond portfolio managed relative to the Bank of America Merrill Lynch 1-10 Year US Corporate & Government Index as its benchmark.
• High Yield Taxable Fixed Income: Actively managed fixed income portfolio that focuses exclusively on the highest quality (BB) component of the high 1 We currently use the services of certain sub-advisors, including those of Envestnet Asset Management, Inc., Evercore Wealth Management LLC, Mar Vista Investment Partners, LLC, Aristotle Capital Management, LLC and SpiderRock Advisors, LLC. yield universe. The portfolio is managed relative to the Bank of America Merrill Lynch 1-10 Year BB Cash Pay High Yield Index as its benchmark.
• Blended Taxable Fixed Income: Actively managed fixed income portfolio that combines TC’s investment grade capability with its high yield (BB) capability. The portfolio is managed relative to a custom blended benchmark comprised of 50% corporate/government intermediate investment grade bonds (as identified in the Bank of America Merrill Lynch 1-10 Year US Corporate & Government Index) and 50% intermediate BB rated bonds (as identified in the Bank of America Merrill Lynch 1-10 Year BB Cash Pay High Yield Index).
• Treasury Bond Ladder: Actively managed strategy that invests in Treasury bonds 1-10 years in maturity.
• Tax-Exempt Fixed Income: Actively managed strategy that focuses on investment grade, short-to-intermediate maturity municipal bonds. The strategy is customized to maximize the after-tax returns for each individual client.
• Taurus: Actively managed growth strategy focusing on above-average growth businesses that are poised to benefit from secular growth trends. The process utilizes a proprietary screen to identify attractive securities alongside fundamental and technical analysis.
• Aware: Actively managed domestic equity portfolio focused on making investments in businesses that meet strict environmental, social and governance (ESG) criteria.
• High and Rising Dividend: Equity strategy which seeks to invest in equity securities of companies that pay relatively high dividends as measured by yield. Stability and/or growth of dividends and dividend yield may also be considered by the manager. The strategy invests across a broad range of market capitalizations. It is primarily designed for taxable investors seeking current income and/or who can benefit from the lower federal income tax rates applicable to dividends and/or long-term capital gains. The strategy may also be appropriate for taxable or tax-exempt investors seeking a different and complimentary income stream, the principal of which can fluctuate greatly. Finally, investors may use this strategy to diversify their equity allocation. Investments are diversified across sections and industries in an effort to reduce the risk of concentrating investments only in industries with the highest dividend yields. Non-Discretionary Advisory Services TC also provides personalized investment management services on a non- discretionary basis at a client’s request. This typically involves selecting or making recommendations as to specific securities or other investments the client’s account(s) should purchase or sell based on the client’s needs and objectives, however, the client must approve the recommendations before the trade is placed. As noted above, investments by clients in affiliated private funds, such as the TLSRE Fund, will be on a non-discretionary basis. Financial Plans Basic financial planning services are included in the wealth management services offered to clients. For clients who are interested in this service, an investment adviser representative (“IAR”) meets with the client and gathers information regarding a client’s financial goals, objectives, risk profile and other pertinent information and provides asset allocation recommendations among different types of securities and non-securities investments. Retirement Plan Review Services TC provides retirement plan advisory services for its clients, which provides clients the opportunity to have TC review and consult on the client’s assets invested in her or his employer’s retirement plan. This provides clients with a consolidated view of their retirement assets. TC 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. TC is also a fiduciary under section 4975 of the Internal Revenue Code (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, TC is subject to specific duties and obligations under ERISA and the IRC 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”). As a fiduciary, we have duties of care and loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. TC and Sentinel Pension Advisors, LLC (“SPA”) have an agreement in place whereby TC serves as a subadvisor to SPA for certain client retirement plans. This arrangement is more fully described in Item 10. TC also provides fee-based wealth management services, including estate tax, social security, education expense planning and asset allocation, as well as other financial planning services to its clients on a non-discretionary basis. In addition to the non-discretionary investment management services described above, TC also offers other non-discretionary advisory services. Clients who utilize our discretionary advisory services may, as an accommodation, also be permitted to establish non-discretionary advisory accounts in which all securities transactions are client-directed. For these accommodation accounts, TC generally charges an annual fee of 20 basis points based on the average daily balance of the account market values for the 12-month period being billed. These assets are not included in the calculation of TC’s regulatory assets under management. Additionally, certain accounts hold assets which the client has directed TC to hold for tax or other purposes. TC provides ongoing and continuous supervision of these client assets. These assets are included in the calculation of TC’s non-discretionary regulatory assets under management. In addition to the above investment management and wealth advisory services, TC also provides a suite of accounting, management, administrative and reporting services to clients, referred to as “Family Office Services” (also called “Virtual Family CFO Services”). These services are customized based on the individual needs of the client. These services are more fully described as follows:
• Accounting and Management Services: Telemus provides hands- on day-to-day oversight and management of clients’ financial affairs, including bill pay and invoice management.
• Administrative Services: Telemus helps organize and maintain clients’ important financial information.
• Reporting: Telemus develops customized, detailed reports that provide meaningful information to help families better understand their overall financial picture. One of these services is Telemus Tax Concierge which assists clients with their tax return preparation requirements. If a client needs a tax preparer to complete his/her returns, Telemus Family Office Services will make an introduction to a qualified CPA. If the client engages the CPA, Telemus will receive a referral fee from the CPA which is disclosed to the client. For clients using this service, Telemus will help in the compilation of source documents and other information needed to complete the client’s return(s). TC also provides a suite of services referred to as “Corporate Executive Services.” These include concierge-like advisory services to senior corporate executives. These services, which in some cases will be in concert with third party service providers, include advisory services relating to the following:
• Compensation and Benefits.
• Estate Planning and Wealth Transfer.
• Risk Management and Insurance.
• Tax Planning and Return Preparation.
• Retirement Planning.
• Investment Planning. TC offers an online investment platform called “Telemus Digital.” It allows clients to complete their personalized risk and suitability assessment and new account paperwork requirements digitally. Once an account is set up, clients still have the benefit of TC’s wealth management services through the assistance of a financial life advisor. In addition, TC offers clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions with the assistance of our affiliate, Focus Treasury & Credit Solutions (“FTCS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. As of December 31, 2022, TC manages approximately $2,972,199,618 in assets for approximately 1,652 clients. This includes approximately $2,391,503,994 managed on a discretionary basis, and approximately $580,695,624 managed on a non-discretionary basis.