Item 5: Additional Compensation ......................................................................................................... 24 Item 6: Supervision .................................................................................................................................. 24 Item 2: Educational Background and Business Experience ............................................................... 26 Item 3: Disciplinary Information ........................................................................................................... 27 Item 5: Additional Compensation ......................................................................................................... 27 Item 6: Supervision .................................................................................................................................. 27 Business Description We provide services to a select group of high-net-worth individuals, families with multigenerational wealth, and endowments including not-for-profit, concerning equities both domestic and non-U.S., fixed income securities, publicly traded real estate funds (including REITs), treasury inflation protected/inflation linked bonds, mutual funds, and ETFs (including ETFs in commodities such as precious metals and oil). As a registered investment adviser, we are held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our client’s interests first and must fully disclose any potential conflict of interest. We do not hold customer funds or securities. A. Description of the Advisory Firm RiverGlades Family Offices, LLC (hereinafter “RiverGlades”) is a Limited Liability Company organized in the State of Florida. The firm was formed in May 2014, and the principal owner is Paul J. Marinelli III. B. Types of Advisory Services Portfolio Management Services RiverGlades offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. RiverGlades creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring RiverGlades evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. RiverGlades will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. RiverGlades seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of RiverGlades’ economic, investment or other financial interests. To meet its fiduciary obligations, RiverGlades attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, RiverGlades’ policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is RiverGlades’ policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. External Chief Investment Officer RiverGlades is available to registered investment advisers and Family Offices as an external Chief Investment Officer. Each engagement will be custom designed to fit the needs of the client firm or Family Office. RiverGlades may act in a discretionary or non- discretionary capacity as a coordinator or manager of Third party Money Managers of the client firm or Family Office to maintain appropriate asset allocations and portfolio structures. If

needed RiverGlades can act as a sub-adviser to any of the existing Third Party Money Managers. Consulting Engagements RiverGlades will work with individuals, families, family offices and not-for-profits on specific projects with timelines not expected to exceed six months. Projects will be outlined and agreed to by the client including expected deliverables. These projects may include but are not limited to ad hoc research on investment securities or third party managers, comprehensive evaluation of existing assets and investment strategy, guidance and advice with developing legacy culture of wealth stewardship, facilitating family meetings, and providing other customized educational opportunities. RiverGlades will typically charge a negotiable flat fee for the project. Selection of Other Advisers RiverGlades may direct clients to third party money managers or hire sub-advisers. RiverGlades will be compensated via its own advisory contract and will not share fees from the advisors to which it directs those clients or sub-advisers that it hires. The fees charged to the client will be a combination of RiverGlades’ advisory contract and the outside manager’s contract with the client. For sub-advisers, RiverGlades and the sub- adviser may separately debit fees. Before selecting other advisors for clients, RiverGlades will always ensure those other advisors are properly licensed or registered as an investment advisor. Services Limited to Specific Types of Investments RiverGlades generally limits its investment advice to equities both domestic and non-U.S., fixed income securities, publicly traded real estate funds (including REITs), treasury inflation protected/inflation linked bonds, and ETFs (including ETFs in commodities such as precious metals and oil). Client exposure to equities, fixed income and non-US securities are primarily through ETFs, not directly in the market. RiverGlades may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions RiverGlades offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent RiverGlades from properly servicing the client account, or if the restrictions would require RiverGlades to deviate from its standard suite of services, RiverGlades reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. RiverGlades does not participate in wrap fee programs. E. Assets Under Management RiverGlades has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 139,629,500 $ 38,475,750 December 2023