Venturi Private Wealth (the “Firm” or “Venturi”) offers a variety of advisory services to help families and clients focus on navigating wealth and the complexities surrounding wealth. Such services include investment management and wealth management, financial planning, consulting, insurance and family office services. In working with clients, the Firm seeks first to evaluate each client’s current, holistic financial situation. Venturi then designs and implements an investment plan aimed at achieving a client’s financial objectives. Prior to Venturi rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Venturi is a privately-owned, independent firm headquartered in Austin, Texas. Venturi has been principally owned by Russell Wayne Norwood and George Lawson Clark since August 14, 2015. One client is a minority owner in the Firm. This client does not receive reduced fees and is not involved in investment decisions. Several employees are also minority stakeholders in the Firm. As of December 31, 2022, Venturi had approximately $2,299,752,097 of regulatory assets under management (“RAUM”), of which $2,265,936,924 was managed on a discretionary basis and $33,815,173 of which was managed on a non-discretionary basis. While this brochure generally describes the business of Venturi, certain sections also discuss the activities of its officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Venturi’s behalf and is subject to the Firm’s supervision or control. Investment and Wealth Management Services Clients typically grant us discretionary authority to manage their accounts by signing Advisory Agreements. Discretionary authority means that we can buy and sell investments on clients’ behalf without seeking permission on a trade-by-trade basis. In limited instances, we may have non-discretionary authority on specific holdings where the client will make the ultimate decision on trading. In addition, the Firm provides clients with wealth management services that include a broad range of comprehensive financial planning services in addition to the discretionary management of investment portfolios. To implement its management services, Venturi allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, options and independent investment managers (“Independent Managers”) in accordance with the client’s stated investment objectives. In addition, Venturi may also recommend that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., limited partnerships). Where appropriate, the Firm may also provide advice about any legacy position or other investment held in client portfolios. Clients also engage Venturi to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Venturi directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. These assets are usually managed by Venturi on a non-discretionary basis. Venturi, as a non-discretionary advisor, offers sponsors of employee benefit plans (defined contribution and defined benefit) qualified under the Internal Revenue Code ("IRC") assistance in selecting plan service providers, investment selection, and monitoring. Once a service provider is selected, we will assist a client in implementing their retirement plan program. In implementing the program, Venturi will review the plan design, develop performance standards, and review the service provider's contract. We may also provide assistance with annual strategic employee education and communications in connection with client retirement plan programs. Venturi tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Venturi consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Venturi if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Venturi determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, Venturi may select certain Independent Managers to actively manage a portion of our clients’ assets. These independent investment managers typically charge fees in addition to our fee and Venturi does not receive a portion of third-party manager fees. Venturi will not have discretion in the selection of securities purchased or sold by such managers. The specific terms and conditions under which a client engages an Independent Manager are usually set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients should also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Venturi evaluates a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent

Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk tolerance. Venturi also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Venturi’s Investment Committee is tasked with initial and ongoing investment manager due diligence for the firm. Venturi continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Venturi seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Financial Planning and Consulting Services Venturi offers clients a broad range of financial planning and consulting services, which may include any or all of the following functions: While these services are generally rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (as described above), clients can engage the Firm to provide these services on a stand-alone basis. In performing these services, Venturi is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Venturi under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Venturi’s recommendations and/or services. Private Fund Management Venturi manages nine private limited partnerships, (“Private Funds”). The Private Funds are offered to Venturi clients and others who qualify for participation. This brochure is not a public offering of the Funds. Please refer to Item 16 below and the Private Fund offering documents for further and specific information. Family Office Services In addition to traditional investment advisory services described in this disclosure document, Venturi also provides Family Office Services to select clients. These Family Office Services encompass both strategic and tactical advisory consulting. Family Office Services may not be offered to all Venturi clients. Family
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Charitable Giving
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Distribution Planning
• Tax Planning
• Manager Due Diligence
• Executive Stock Planning Office clients generally are families with $50 to $100 million in net wealth who have complex financial issues and require financial services beyond investment management, such as strategic planning and family governance, cash management, tax organization and analysis, risk management, trust and estate planning and administration, philanthropic consulting, and household employee administration, and concierge service analysis. To the extent requested by Client and within the scope of services, Venturi shall consult with Client’s attorneys, tax advisors, and other advisors to arrive at solutions designed to help Client meet his, her, or its goals. However, Venturi shall not provide legal or tax advice. Venturi offers comprehensive family office services including but not limited to:
• Family Governance and Decision Making
• Cultures, Values, and Vision Alignment
• Wealth Strategy, Asset Protection & Portfolio Implementation
• Learning and Development
• Philanthropic Consulting
• Estate Planning
• Tax Planning & Projections
• Cash and Liquidity Management
• Banking and Credit Consulting
• Lifestyle Service
• Liquidity and Exit Planning Family Office Services are not performed in conjunction with our investment supervisory or investment management services, nor the regular review or monitoring of your investment portfolio. Family Office Services and are provided pursuant to a separate Agreement for Family Office Services and governed by the express terms thereunder. See Item 5, Fees and Compensation, so that clients and prospective clients (“client” or “you”) can review the services and description of the fees more thoroughly. Business Advisory Services Venturi offers clients business advisory services that are fully customized and defined projects for personal business matters in private business evaluations, financial performance assessment including modeling, investment due diligence, and M&A pre-planning, among others. Our business advisory services are not performed in conjunction with our investment supervisory or investment management services, nor the regular review or monitoring of your investment portfolio. Fiduciary (3(21)) Services to Retirement Plan Sponsors Venturi provides pension consulting services to plan sponsors of profit sharing and 401(k) plans. All pension consulting services will be outlined in a 3(21) advisory agreement that shows the services that will be provided and the fees that will be charged for those services. Venturi will assume the duties of a fiduciary “investment adviser” (as such term is defined in Section 3(21) of ERISA). Venturi will assist and provide guidance to the plan administrator or plan sponsors on a non-discretionary basis to identify and select among investment styles and options and help monitor their investments on an ongoing basis. The plan sponsor/trustee retains ultimate decision-making authority for the investments and may accept or reject the recommendations. Plan assets invested in mutual funds or other investment companies, or investment funds may also be subject to additional advisory fees, management fees and other expenses, as set forth in the prospectuses of such funds, and are paid by the Plan in addition to the fees charged by Adviser under this Agreement.