A. Firm Information Summit Trail Advisors, LLC (“Summit Trail” or the “Advisor”) is a limited liability company formed on July 6, 2015 in the state of Delaware. Summit Trail is a wholly owned subsidiary of Summit Trail Holdings, LLC and is operated by Jack Petersen (Managing Partner), David Romhilt, CFA (Chief Investment Officer) and Thomas Harms (Chief Compliance Officer). The Advisor became a registered Investment advisor with the U.S. Securities and Exchange Commission (“SEC”) in June 2015. The Advisor’s Chief Compliance Officer (“CCO”), Thomas Harms, remains available to address any questions that a Client or prospective Client may have regarding this Disclosure Brochure. B. Advisory Services Offered The Advisor offers investment advisory services and, to the extent specifically requested by a Client, financial planning and related consulting services to individuals, business entities, trusts, estates, charitable organizations, and pension and profit sharing plans (each a “Client”). In the event that the Client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of the Advisor), the Advisor may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written agreement with the Client. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Advisory Services The Client can determine whether to engage the Advisor for investment advisory services on a discretionary and/or non-discretionary basis. Clients who choose to engage the Advisor on a non- discretionary basis must be willing to accept that the Advisor cannot execute any account transactions without obtaining prior consent to any such transaction(s) from the Client. Therefore, in the event that the Advisor would like to make a transaction for a Client’s account, and Client is unavailable, the Advisor will be unable to execute the account transaction (as it would for its discretionary Clients) without first obtaining the Client’s consent. As part of its investment advisory services, Summit Trail will review Client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the Client’s investment objective. Based upon these 5 | Summit Trail Advisors, LLC March 28, 2024 factors, Summit Trail can determine that during extended periods of time changes to a Client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Summit Trail will be profitable or equal any specific performance level(s). Summit Trail continues to treat cash as an asset class. As such, unless determined to the contrary by Summit Trail, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Summit Trail’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Summit Trail, depending on the needs or circumstances, may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Summit Trail’s advisory fee could exceed the interest paid by the Client’s money market fund. Summit Trail selects, recommends and/or retains mutual funds on a fund-by-fund basis and seeks to use non-retail or institutional classes when possible. Due to specific custodial or mutual fund company constraints, material tax consideration, and/or systematic investment plans, Summit Trail may select, recommend or retain a mutual fund share class that has a higher expense ratio than an equivalent share class, as described in Item 5. Summit Trail will seek to select the lowest cost share class available that are in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guideline. Use of Independent Managers – For those Clients that require an enhanced and/or specialized level of investment management services, the Advisor may also recommend that certain Clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment manager(s) (“Independent Managers”). To the extent applicable, the Advisor shall recommend Independent Managers consistent with the Client’s investment objectives. Factors which the Advisor shall consider in recommending Independent Managers include the Client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The Advisor shall continue to render advisory services to the Client relative to the ongoing monitoring and reviewing of account performance, for which the Advisor shall receive an annual advisory fee per Item 5 below which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. Clients who choose to engage the Advisor and elect to utilize Independent Managers will incur costs in addition to the Advisor’s advisory fee. Management fees charged by Independent Managers, together with the fees charged by the broker-dealer/custodian of the Client’s assets, and any independent manager platform provider fee are exclusive of, and in addition to, Advisor’s investment advisory fee. Additionally, the Advisor may provide investment advisory services to executives and/or principals of certain unaffiliated Independent Managers, thereby creating a conflict of interest. To the extent that the Advisor believes that the utilization of these investment managers is appropriate for a 6 | Summit Trail Advisors, LLC March 28, 2024 Client, the Advisor shall disclose the conflict to the Client and give the Client the right to restrict, in writing, the Advisor’s use of an Independent Manager. Private Fund Investments - The Advisor provides investment advice or investment relation services regarding affiliated and unaffiliated private investment funds. Unaffiliated Funds – The Advisor’s role relative to any unaffiliated private investment fund shall be limited to its initial and ongoing due diligence and investment monitoring services. If a Client determines to become an investor in an unaffiliated private fund, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee per Item 5 below (unless the Client purchases the fund from the Advisor’s affiliated broker- dealer, where a separate placement fee is assessed - see disclosure under Item 10 below). The Advisor’s Clients are under no obligation to consider or make an investment in an unaffiliated private investment fund(s). Affiliated Funds - The Adviser is the General Partner and/or Investment Advisor to various private funds issued by Ascent Private Capital Management (the Affiliated Fund[s]). If a Client determines to invest in an Affiliated Fund, the amount of assets invested in the Affiliated Fund shall be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee per Item 5 below. The Advisor’s Clients are under no obligation to consider or make an investment in an Affiliated Fund. The Advisor does not receive a separate advisory fee or other forms of compensation for its investment advisory services to any Affiliated Funds. Rather, the Advisor’s only compensation is the advisory fee that it receives from any value included as a part of assets under management. Outsourced Chief Investment Officer Services Institutional Clients may engage the Advisor for Outsourced Chief Investment Officer services (“OCIO Services”). The OCIO Services assist institutional fiduciaries in defining investment policies and objectives, selecting investment managers, and monitoring and evaluating investment performance of the End Retail Clients of the Institutional Clients. The OCIO Services is expressly limited to investment consulting services and does not include financial planning or any other related or unrelated services. It shall remain solely up to the Institutional Client to determine whether the Advisor’s recommendations are suitable given the End Retail Client’s total investment holdings. In the event that the Advisor is requested to provide consulting services with respect to investments in a retirement plan for an End Retail Client, the Advisor’s recommendations shall be limited to the investment options provided by the retirement plan. The Advisor does not provide the implementation of any of its OCIO services unless otherwise explicitly agreed to between the Advisor and the Institutional Client in writing. Institutional Clients enrolled in the OCIO Services maintain the exclusive responsibility to accept/reject or implement any of the Advisor’s recommendations or advice under the OCIO Services. Under the OCIO Services, Institutional Clients may also engage the Advisor for access to certain advisory products offered by the Advisor such as private fund investments, model portfolios and 7 | Summit Trail Advisors, LLC March 28, 2024 other Advisor-managed investment vehicles. Additionally, the End Retail Client may also engage the Advisor individually for their investment advisory services. Each of the services and engagements described in this section are at the Client’s discretion. Financial Planning and Consulting Services As a part of its investment management services, the Advisor may provide Clients financial planning and/or consulting services. Clients can also engage the Advisor for stand-alone financial planning services and related consulting services regarding non-investment related matters, including, but not limited to, estate planning, tax planning and insurance needs. Prior to engaging the Advisor to provide stand-alone financial planning or consulting services, Clients are generally required to enter into a Financial Planning and Consulting Agreement with Advisor setting forth the terms and

conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the Client prior to Advisor commencing services. If requested by the Client, the Advisor may recommend the services of other professionals for implementation purposes (i.e., attorneys, accountants, brokers, insurance agents, etc.). The Client is under no obligation to engage the services of any such recommended professional. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Advisor or its Advisory Persons. If the Client engages any such unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Advisor, shall be responsible for the quality and competency of the services provided. Additionally, it remains the Client’s responsibility to promptly notify the Advisor if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Advisor’s previous recommendations and/or services. If the Advisor has been engaged to provide non-discretionary consulting services relative to Client investment assets for which the Advisor does not maintain any trading authority, including assets managed by the Client’s other unaffiliated investment professionals, (the “Excluded Assets”), the Client and/or the Client’s other investment professionals/advisors that maintain trading authority, and not the Advisor, shall be, and remain, exclusively responsible for the investment performance of the Excluded Assets. The Advisor shall not be responsible for the actions and/or omissions of the Client’s other investment professionals/advisors. The Client is under absolutely no obligation to accept any of Advisor’s advice or recommendations relative to the Excluded Assets. In the event the Client desires that the Advisor provide investment management services for the Excluded Assets, the Client may engage the Advisor to do so pursuant to the terms and conditions of the Investment Advisory Agreement between the Advisor and the Client.
8 | Summit Trail Advisors, LLC March 28, 2024 The Advisor, in conjunction with the services provided by third-party services, may also provide periodic reporting services which can incorporate all of the Client’s investment assets, including Excluded Assets. Unless otherwise specifically agreed to, in writing, Advisor’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if the Advisor is specifically engaged to monitor and/or allocate the assets within the Client’s 401(k) account maintained away at the custodian directed by the Client’s employer. As such, except with respect to the Client’s 401(k) account (if applicable), Advisor does not maintain any trading authority for the Excluded Assets. Rather, the Client and/or the Client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. In the event the Client desires that Advisor provide investment management services for the Excluded Assets, the Client must engage the Advisor to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Advisor and the Client. The Advisor also offers a full suite of family office services to Clients. These services are offered in combination of investment management services or can be delivered as a separate service, pursuant to a written agreement. Clients have the option to select from menu of services, which include but are not limited to: Active Estate Management – Aggregates family and financial information to develop plans and investment solutions for address overall needs and objectives. Advisor Coordination – Support services including coordination of advisory teams (banks, legal, insurance, tax accountants, family services, benefit organization), due diligence support, and accounting support. Reporting – Dashboard created to help navigate financial and legal landscape, consolidated balance sheets, estate plan analysis, and maintaining relevant documentation. Philanthropy – Assist with philanthropic goals through account structure and funding, grant review and administration and investment opportunities. Cash Management – Assist with cash and lending needs. Tax Management – Coordination and oversight of personal tax planning and tax preparation services, which includes; estate planning, trusts and foundations, residential and lifestyle management and insurance. Benefits – Assess and help implement cost effective and efficient corporate benefits plans. Summit Trail does not serve as an attorney or accountant, and no portion of our services should be construed as same. Accordingly, Summit Trail does not prepare legal documents or tax returns. 9 | Summit Trail Advisors, LLC March 28, 2024 Retirement Plan Advisory Services Summit Trail provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations by providing education services to the Plan and its Plan Participants. These services are provided by Summit Trail serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Summit Trail’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Miscellaneous Retirement Plan Rollovers – No Obligation / Conflict of Interest: A Client or prospective Client leaving an employer typically has four options regarding an existing retirement plan (and has the ability to engage in a combination of these options): (i) leave the assets in the former employer’s retirement plan, if permitted, (ii) rollover the assets to the new employer’s retirement plan, if one is available and rollovers are permitted, (iii) rollover to an individual retirement account (“IRA”), or (iv) cash out the account value (which could, depending upon the Client’s age, result in adverse tax consequences). If the Advisor recommends that a Client roll over their retirement plan assets into an account to be managed by the Advisor, such a recommendation presents a conflict of interest if the Advisor will earn new (or increase its current) compensation as a result of the rollover. The Advisor does not generally provide recommendations to Clients on rollovers. However, If Advisor provides a recommendation as to whether a Client should engage in a rollover or not, Advisor is acting as a fiduciary 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. No Client is under any obligation to rollover retirement plan assets to an account managed by the Advisor. C. Client Account Management The Advisor shall provide investment advisory services specific to the needs of each Client. Prior to providing investment advisory services, an Advisory Person will ascertain each Client’s investment objective(s). Thereafter, the Advisor shall allocate and/or recommend that the Client allocate investment assets consistent with the designated investment objective(s). The Client may, at any time, impose reasonable restrictions, in writing, on the Advisor’s services. Cash Sweep Accounts: Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Advisor shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless the Advisor reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the Client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the 10 | Summit Trail Advisors, LLC March 28, 2024 Client of an imminent need for such cash, or the Client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within an actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the Client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The Client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any unmanaged accounts. D. Wrap Fee Program The Advisor no longer offers a Wrap Fee Program to new Clients, however, the Advisor has a legacy Client where securities transaction fees are combined with investment advisory fee into a single asset-based fee. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. E. Assets Under Management As of December 31, 2023, the Advisor had assets under management of $17,651,630,433. This includes $7,351,611,599 of which is managed on a discretionary basis and $10,300,018,834 on a non-discretionary basis. $20,847,700,144 is the combined assets under management and approximate total assets under advisement. The approximate assets under advisements include, but are not limited to, personal property, outside investments and other real assets. These are non-GAAP accounting assets and values are derived from information provided by the families we represent and are not verified by STA. Clients may request more current information at any time by contacting the Advisor.