Introduction SVB Wealth LLC (“SVBW” or “we” or “us”), a Massachusetts limited liability company, is an investment adviser registered with the United States Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). SVBW is a wholly owned, non-bank subsidiary of First-Citizens Bank & Trust Company (“FCB”), which in turn, is a wholly owned subsidiary of First Citizens Bancshares, Inc., a publicly traded company (NASDAQ: FCNCA). Previously, SVBW was owned by Silicon Valley Bridge Bank, N.A. (“SVBB”), a full- service FDIC-operated ‘bridge bank’ chartered by the Office of the Comptroller of the Currency as a national bank, and prior, Silicon Valley Bank (“SVB”), which was closed by the California Department of Financial Protection and Innovation. Upon the closure of SVB, the Federal Deposit Insurance Corporation (the “FDIC”), as the appointed receiver, transferred substantially all of the assets of SVB to SVBB on March 13, 2023. SVBW has been in business since 2014, originally operating as Boston Private Wealth LLC (“BPW”), a subsidiary of Boston Private Financial Holdings, Inc. (“BPFH”). In 2021, SVBW’s former parent company, SVB, acquired BPFH and as part of the integration, BPW changed its name to SVB Wealth LLC in 2022. This Brochure describes the investment advisory services offered by SVBW. SVBW’s advisory services are made available to clients primarily through its “Private Wealth Advisors” (collectively referred to herein as Private Wealth Advisors and each, a Private Wealth Advisor). Private Wealth Advisors are individuals associated with SVBW as investment adviser representatives. Some Private Wealth Advisors are also registered representatives of First Citizens Investor Services, Inc (“FCIS”), an SEC-registered broker-dealer and a member of the Financial Industry Regulatory Authority (“FINRA”). As of December 31, 2023, SVBW had the following regulatory assets under management: Discretionary $ 6,464,656,324 Non-Discretionary $ 165,509,644 Total $ 6,630,165,968 Types of Advisory Services SVBW offers discretionary and non-discretionary investment advisory services. Client accounts for which SVBW serves as investment adviser are referred to throughout this Brochure as “Advisory Accounts” and/or “Accounts” (and each, an “Advisory Account “or “Account”). Clients who wish to open and maintain an Advisory Account and receive any of the investment advisory services discussed in this Brochure are required to enter into the applicable SVBW investment advisory client agreement (the “Client Agreement”), which sets forth the services that SVBW (and, if applicable, the Investment Manager(s) (as defined below)) will provide to the client, the obligations of SVBW in providing such services, and acknowledgement of the investment advisory relationship between SVBW and the client. The specific terms and conditions of the Client Agreement will govern each client’s Advisory Account and the investment advisory relationship between the client and SVBW and, as applicable, other parties to the Client Agreement with respect to the Advisory Account(s). The investment advisory services that SVBW offers can be provided on either a discretionary or non-discretionary basis. Non- discretionary advisory services are intended for clients who want to receive ongoing investment advice for a fee but wish to retain ultimate decision-making authority over the trading activity in their Account(s). These non-discretionary services include providing investment advice and specific asset allocation and/or investment recommendations based on a client’s investment objectives, risk tolerance, financial circumstances and other information clients provide to SVBW when establishing an Advisory Account. Under a non-discretionary relationship with SVBW, SVBW will provide the ongoing and continuous investment advice and guidance to the client as memorialized by the Client Agreement, and it will be the client’s decision whether SVBW’s investment advice and recommendations are implemented in their Account(s). SVBW provides a broad range of investment management and advisory services and offers investment analysis and portfolio construction over a broad range of investment styles. Our investment offerings include equities, fixed-income securities, mutual funds, exchange-traded funds (“ETFs”), private funds, and derivatives, as well as various investment strategies of certain unaffiliated, third-party Investment Managers (defined below). Investment offerings vary by service and certain offerings are subject to investment minimums and/or specific eligibility requirements and therefore may be limited based on one or more factors such as a client’s personal financial situation, amount, and type of assets available to invest, and/or account value. For example, pursuant to applicable rules and regulations, private fund offerings are only available to qualified clients who meet certain eligibility requirements related to financial sophistication and net worth, among others. SVBW manages investment portfolios comprised of various strategies and investment types, including individual stocks and fixed income securities as well as investment vehicles, such as mutual funds, ETFs and private investments funds, that invest in equities, fixed income securities, and underlying pooled investment vehicles. Our full-service investment management clients receive our wealth advisory & financial planning services at no additional charge. Custom Portfolio Management Services SVBW’s approach to investment management begins with a review and assessment of each client’s specified investment objective(s), risk tolerance, and investment time horizon. After this assessment, we recommend a custom investment portfolio, which can include individual equities, individual fixed-income securities, mutual funds, ETFs, and/or limited partnerships and similar pooled investment vehicles. The overall asset allocation is determined by the client’s investment objectives as described above; the appropriate risk tolerance is then defined based on that assessment, and falls within one of the following six categories: Aggressive Growth | Growth | Balanced Growth Balanced Income | Income | Conservative Income In creating these customized portfolios, certain of SVBW’s proprietary investment strategies, as described below, may be used to fulfill certain allocations. SVBW’s custom portfolio management services also include a comprehensive review of each client’s existing holdings and asset mix to implement a streamlined and tax efficient transition of client assets and/or securities – all aligned to the client’s personal investment objectives. Each client will be served by one or more Private Wealth Advisors who are trained to respond specifically to Part 2A of Form ADV: Firm Brochure – March 31, 2024 | Page 5 of 18 each client’s unique requirements. Concentrated Holdings Services For clients who seek advice related to concentrated security holdings, SVBW provides analysis, research, monitoring, and active management and will design diversification strategies for clients with concentrated securities holdings. Our services for management of concentrated securities holdings are provided on a pre-approved basis and require a preliminary review of the client’s portfolio by one of our investment professionals. If suitable, as part of these services, we may also recommend the use of options strategies. Clients should be aware that the use of options presents additional risks as described below in Item 8. As such, the recommendation and use of options strategies for clients is on a limited basis, as suitable and appropriate for any such client. Proprietary Separate Account Strategies SVBW offers a suite of proprietary separate account strategies that may utilize individual equities and/or fixed income securities as well as strategies that invest in ETFs and/or mutual funds. These strategies are designed to provide a foundation for client’s investment portfolios through both diversification and active management. These proprietary separate account strategies may be used exclusively or in combination with other strategies within the client’s aggregate portfolio. Our proprietary separate account strategies are managed in accordance with the client’s specified investment objective(s) and risk tolerance for an Account. The investments utilized for a proprietary strategy are selected based on achieving the stated objective(s) of the specific strategy. The use of, and allocation to, SVBW’s proprietary strategies in a client’s portfolio will be chosen based on the client’s overall risk tolerance, time horizon, and investment objective(s). SVBW’s professionals will offer specific guidance about which strategy or combination of strategies will be best suited to each client’s investment objectives, risk tolerance and investment time horizon, among other things, and the proper allocations within the client’s portfolio framework. Third-Party Investment Managers SVBW may recommend the allocation of a portion of a client’s investment assets among one or more unaffiliated, third-party investment managers (each, an “Investment Manager” and collectively, “Investment Managers”) in accordance with a client’s investment objective(s), risk tolerance and financial situation. SVBW maintains a disciplined research and due diligence process to identify Investment Managers that offer investment strategies (each, a “Strategy” and collectively, “Strategies”) that we believe provide opportunities not available through, or more appropriate than, investment vehicles such as ETFs or mutual funds. As discussed in Item 8 below, factors which our investment team considers in selecting and recommending Investment Managers to our advisory clients include, but are not limited to, the management style, investment and overall performance, reputation, financial strength, reporting, pricing, and research of each such Investment Manager, as well as a client’s designated investment objective(s). The Investment Manager shall have day-to-day responsibility for the active discretionary management of the client Accounts invested in their Strategy or Strategies. SVBW shall continue to render investment advisory services to the client through the ongoing monitoring and review of account performance, asset allocation and client investment objectives. SVBW maintains ongoing annual due diligence and review over the recommended Investment Managers. Before a client establishes an Account with an Investment Manager, the client will receive the Form ADV Part 2A Brochure (or other applicable disclosure document) for such Investment Manager which contains information regarding its fees, services, methods of analysis, Strategies, and other important information. SVBW enters into sub-advisory agreements with the Investment Managers it recommends for client portfolios. This means that SVBW has discretionary authority to hire and/or fire the Investment Manager on behalf of clients and results in some operational efficiencies regarding the opening and closing of accounts as well as communicating transaction details. As discussed below in Item 5, each Investment Manager charges its own advisory fee which is deducted from a client’s Account at the customary billing intervals. SVBW does not receive any compensation from any Investment Manager. As detailed below in Item 5, the investment advisory fee that a client pays to SVBW does not include the fees charged by each available Investment Managers. The Form ADV Part 2A Brochure for each Investment Manager is available at the SEC’s website at https://www.adviserinfo.sec.gov/IAPD. Clients are encouraged to review each Investment Manager’s disclosure documents for important additional information. Private Investment Funds Some clients prefer the ability to access private investment funds. SVBW offers eligible clients access to certain unaffiliated private investment funds. SVBW will only recommend private funds to those clients who meet the regulatory requirements and thresholds (i.e., Accredited Investor, Qualified Client, or Qualified Purchaser) to be eligible to invest in such private funds, and for whom SVBW reasonably believes such an investment to be suitable, given the client’s total portfolio, investment objectives, risk parameters/tolerance and liquidity needs. SVBW shall not exercise any discretion whatsoever related to a client’s decision to invest in any private fund. Rather, the decision to invest in any private fund is made by the client and is the client’s responsibility. SVBW’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of SVBW calculating its investment advisory fee. SVBW clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Any clients deciding to invest in a private fund will receive an

offering memorandum, or other similar document, prepared by the fund sponsor outlining the fund’s investment objectives, risk factors, conflicts, and the terms of the investment in such private fund. For each private fund in which a client decides to invest, the client will sign and enter into the Client Agreement with SVBW and will also be required to sign separate fund documentation (i.e., a subscription agreement or other similar agreement) for each such private fund acknowledging the terms and conditions of the fund and/or venture and the corresponding risk factors, including loss of principal and liquidity constraints. Investments in private investment funds involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency. A complete description of such risks is set forth in each fund’s offering Part 2A of Form ADV: Firm Brochure – March 31, 2024 | Page 6 of 18 documents, which are provided to prospective investor clients for review and consideration. Unlike liquid investments, private investment funds do not provide daily liquidity or pricing. As with all recommendations made in our capacity as investment adviser, before recommending a private fund to any client, SVBW must determine whether a specific private fund is suitable for, and in the best interest of, a particular client. In so doing, SVBW shall consider the following factors: – The type of offering-including risks, time horizon, and liquidity issues. – The client’s investment objective(s) – realizing that for certain clients, a private fund of any kind may not be suitable; – The client’s current portfolio allocation; – The client’s available cash to commit to the private fund; – The private fund’s investment minimum per investor; and – The client’s current allocation to private investment funds. – Any supplemental account reports prepared by SVBW shall reflect the most recent valuation provided by the fund sponsor for each private investment fund owned by the client. Wealth Advisory & Financial Planning Services SVBW, in partnership with FCB, offers a range of wealth management and financial planning services which provide clients with advice and information aimed to help them make informed decisions about their entire net worth or components of their net worth. The wealth advisory and financial planning platform has a flexible framework which allows us to customize our approach and the services provided to meet the unique goals and objectives of clients. Our internal wealth advisory and financial planning team includes professionals who are trained to advise clients on a wide variety of matters related to wealth and financial planning. Depending on the particular needs of a client, the SVBW advisory and financial planning team can provide comprehensive financial planning review services as well as periodic financial planning reviews to assess a client’s financial situation, goals and objectives. These services include advice related to one or more of the following: – Income and retirement planning – Protection planning – Investment management planning – Legacy and estate planning – Philanthropic planning – Business succession planning – Executive planning – Estate plan analysis and review – Insurance and risk management review – Cash flow and debt management – Compensation and benefits – Donor advised funds Investment Consulting Services SVBW also provides investment consulting services designed to assist clients in creating and implementing an organized, long-term strategy to make informed decisions about their entire net worth or components of their net worth. Specific investment consulting service options include, but are not limited to, the following: Diagnostic Review – Review client’s current investment process and/or investment advisory engagements – Provide executive summary of our observations and recommendations – Investment policy development and governance design – Investment council/committee design – Asset allocation strategy recommendations Portfolio Construction and Implementation – Access to the other investment advisory and investment management services of SVBW (as detailed above), including proprietary equity and fixed-income investment strategies and Strategies of third-party Investment Managers – Concentrated security management Performance Measurement, Reporting, and Analysis – Custom benchmarking and reporting – Strategy performance analytics Custom Investment Solutions – Customized security research – Access to platform of Investment Managers As part of our investment consulting services, SVBW may also provide discretionary investment advisory services in combination with other (non-discretionary) investment consulting services. Services to Retirement Plan Assets Upon request, SVBW also provides investment advisory services on a client’s 401(k) or similar retirement plan assets. For these clients, SVBW shall make recommendations to the client on the allocation of the retirement account assets among the investment options available on the applicable retirement plan platform. Please note: SVBW’s services shall be limited to the recommendation of allocation of the client’s 401(k) plan or similar retirement plan assets among the investment choices available through the plan. SVBW will not receive any communications from the 401(k) plan or similar retirement plan sponsor or custodian, and it shall remain the client’s obligation to notify SVBW of any changes in investment option changes, investment option restrictions, or other relevant or material information pertaining to the retirement account. IRA Rollovers or Transfers In appropriate circumstances, SVBW may recommend that a client roll over an account held in a former employer’s retirement plan or an outside Individual Retirement Account (“IRA”) to an IRA for SVBW to manage. If the client elects an IRA rollover or transfer subject to SVBW’s management, the account will be subject to SVBW’s advisory fee per the Client Agreement. Many employers permit former employees to keep their retirement assets in the company plan, and some retirement plans permit current employees to move assets out of the company plan before retiring or leaving the company. In determining whether to complete an IRA rollover, and to the extent the following options are available, clients should consider their costs and benefits. An employee will typically have four options: 1. Leave the assets in the employer/former employer’s plan; 2. Transfer the funds to a new employer’s retirement plan; 3. Cash out and take a taxable distribution from the plan; 4. Roll the funds into an IRA account. Each of these options has advantages and disadvantages, and SVBW recommends that clients communicate with their own legal, tax, and/or accounting advisors to consider the options specific to their own situation before making a change. Clients should consider the following relevant issues together with their Private Wealth Advisor and their own personal tax, legal, and/or accounting Part 2A of Form ADV: Firm Brochure – March 31, 2024 | Page 7 of 18 advisors before initiating a rollover or transfer to a SVBW IRA: – Whether the investment options in the employer retirement plan or existing IRA address client’s needs or whether other types of investments are needed. – Employer retirement plans generally have a more limited investment menu than IRAs. – Some employer retirement plans have unique investment options not available to the public such as employer securities, or previously closed funds. – Whether the employer retirement plan or existing IRA has lower management and investment fees and expenses than SVBW. If interested in investing only in mutual funds, clients should understand the cost structure of the share classes available in the employer retirement plan compared to those available in an IRA. – Clients should understand the various products and services available through a SVBW managed IRA and the potential costs of those products and services. – Clients should consider if SVBW’s recommended strategy entails higher risk than the option(s) provided in their employer retirement plan or existing IRA and whether the level of risk is consistent with their current risk tolerance and investment objectives. – If the employer retirement plan or existing IRA offers financial advice. – Keeping assets in an employer retirement plan may potentially delay a required minimum distribution beyond age 72 if the client is still working for the employer. – For clients concerned about protecting assets from creditors, an employer retirement plan may offer more liability protection than an IRA. Such legal protection varies by state. – Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there may exceptions to these general rules so an attorney should be consulted if the client is concerned about protecting their retirement plan assets from creditors. – If loans may be available from the employer retirement plan (although generally loans are not to available ex-employees); no loans are available from an IRA. – When considering accessibility for an IRA versus an employer retirement plan, it’s important to evaluate how accessibility needs align with the rules governing each type of account. – Employer plans may have more stringent rules on withdrawals and may require that the account holder reaches a certain age, no longer works for the employer, or meets other plan-specific criteria. – IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless qualifying for an exception such as disability, higher education expenses or the purchase of a home. – If a client owns company stock in their employer retirement plan, they may be able to liquidate those shares at a lower capital gains tax rate. – If the client’s employer retirement plan allows SVBW to be hired as the investment manager and to keep the assets titled in the plan name. – It is important that clients understand the differences between these types of accounts and to evaluate whether a rollover is best under the circumstances. See Item 10 below for more information regarding conflicts of interest associated with rolling over or transferring employer retirement plan assets or IRA accounts to a retirement account managed by SVBW. Retirement Plan Advisory Services In addition, a team comprised of certain SVBW Private Wealth Advisors known as the Retirement Plan Advisory Team (the “RPA Team”) specializes in providing counseling and advice to businesses on effective plan governance and delivery of employee retirement benefits subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The RPA Team provides services to assist plan sponsors, plan trustees, and investment committees to meet their fiduciary responsibilities. The investment advisory services provided by the RPA Team include preparation of investment policy statements, evaluation, selection, and reporting of investments, and advising clients on education and communication with plan participants. The RPA Team counsels plan fiduciaries with its expertise in plan governance, risk assessment, and expense analysis. Wrap-Fee Program SVBW sponsors a wrap fee program in partnership with an unaffiliated third-party, Betterment LLC (“Betterment”), that is not described in this Brochure. In this program, Betterment, acting as sub-adviser, provides discretionary portfolio management and asset allocation services to clients based on each client’s specific goals, investment objectives, risk tolerance, and other information. Clients pay an asset-based, all-inclusive “wrap” fee that covers the costs of Betterment’s investment advisory services as well as associated trading and custody services provided by its affiliated broker-dealer, Betterment Securities. Information about this program is contained in our Appendix 1 Wrap Brochure, which can be obtained upon request from a Private Wealth Advisor, or at the SEC’s website at www.adviserinfo.sec.gov/IAPD. Reasonable Investment Restrictions With respect to most advisory services described in this Brochure, clients may seek to impose reasonable investment restrictions on the management of their Account assets, including requesting, in writing, particular securities that should not be purchased for an Account (by providing a ticker for any such security), and/or requesting, in writing, a reasonable level of limitation on the discretionary authority granted to SVBW for an Account (e.g., limit the types/amounts of particular securities purchased for a client’s Account) which will be accommodated where practicable. For clients participating in a specific proprietary model or strategy, SVBW will attempt to accommodate requested reasonable limitations and investment restrictions to the extent possible or practicable.