A. Description of Firm Lido Advisors, LLC, d/b/a Lido (“Lido”) is an SEC-registered, Los Angeles-based investment advisor founded in 20011. Lido offers a variety of investment advisory and financial-related services, including, but not limited to, investment management and asset allocation, financial planning, family office services, and retirement and estate planning services. Lido offers these services to high-net-worth and ultra-high-net worth individuals, family offices, pensions, defined benefit plans, profit-sharing plans, trusts, estates, charitable organizations, corporations and other types of business entities, and pooled investment vehicles. Lido offers these services directly or through the following affiliated entities or doing business as (“d/b/a”) names (collectively, the “Lido Companies”):
• Colorado Financial Management, A Lido Company, a Lido d/b/a that provides investment advisory services to primarily clients in the Mountain West region of the United States;
• Enterprise Trust and Investment Company (“Enterprise”), a wholly owned California-chartered trust company based in Los Gatos, California, offering trust and fiduciary services to Lido clients and others;
• Lido Administrative Services, LLC (“L-Administrative”), a wholly owned subsidiary of Lido, that provides operational, compliance, legal services, among others, to certain pooled private investment vehicles;
• Lido Pay, LLC (“L-Pay”), a wholly owned subsidiary of Enterprise, that provides for accounting and bill payment services;
• Lido Tax, LLC (“L-Tax”), a wholly owned subsidiary of Lido, provides tax consulting services to Lido clients.
• Oakhurst Strategies, LLC (“Oakhurst Strategies”), a wholly owned subsidiary of an affiliated Lido company and Lido d/b/a name, that provides primarily options-based strategies to institutional clients. The Lido Companies have more than 30 offices located across the United States including the corporate headquarters in Los Angeles and offices in Boca Raton, Boulder, Chicago, Dallas, Los Gatos, New York City, and San Diego. Lido conducts business in states reflected in its Form ADV Part 1A (copy available upon request or at https://adviserinfo.sec.gov). Lido is majority-owned by certain pooled investment vehicles advised by affiliates of Charlesbank Capital Partners LLC, a middle-market private equity firm. Jason Ozur, Chief Executive Officer, Ken Stern, President, Gregory Kushner, Chairman and Founder, and other Lido employees directly or indirectly own the substantial remainder of Lido. B. Advisory Services 1. Investment Management Lido generally utilizes an integrated wealth management approach to seek to help our clients achieve their financial goals while aiming to reduce market risks and manage volatility, though some clients may choose a more limited range of services. To that end, Lido employs select assets for our clients that are intended to be less correlated to one another, which can include a combination of fixed income2, equities3, cash4, foreign securities, American depository receipts, real 1 Lido operated as Lido Advisors, Inc., prior to July 1, 2015. 2 Fixed income includes, but is not limited to, government bonds, municipal bonds, corporate bonds, high-yield bonds, foreign bonds, preferred stocks, certificates of deposit (“CDs”), loans, exchange-traded funds (“ETFs”) based on bond indices, fixed-income mutual funds, short-term fixed-income instruments, structured notes, and certain preferred stocks. 3 Equities includes, but is not limited to, common stocks, ETFs based on stock indices, equity mutual funds, publicly traded master limited partnerships, and publicly traded royalty trusts, and publicly traded real estate investment trusts (“REITs”). 4 Cash includes, but is not limited to, money market funds, certain mutual funds or ETFs, or other cash equivalents. LIDO ADVISORS FIRM BROCHURE (PART 2A OF FORM ADV) I 2024 4 estate debt, hybrid offerings5, and alternative investments, such as liquid6 and non-liquid7 alternative investments and non-liquid fixed-income investments8 through certain main strategies, including:
• Core Equity Strategy is comprised of equity securities, including, but not limited to, single company stocks, mutual funds, and ETFs, that account for certain geographies, market capitalization, economic cycles, and momentum and fundamental drivers, among other factors, to identify tactical opportunities.
• “Cap and Cushion” is an options-based equity strategy that seeks to limit potential losses by employing downside protection and upside participation through options. Lido deploys this strategy and variations of this strategy (which strategy variations, although thematically similar, are materially distinguishable from Cap and Cushion) directly in client accounts and through affiliated private funds (“Lido Private Funds”).
• Fixed Income is a strategy that seeks the potential for current income and reduction in risk, such as duration and credit risk, by using various fixed-income securities, including, but not limited to, bonds, mutual funds, and ETFs.
• Alternative Investments is a strategy that seeks to provide diversification and can, under the right circumstances, achieve results uncorrelated to equity and fixed-income strategies.
• The Lido Companies’ Strategies. Lido also utilizes additional equity- and fixed-income-based strategies that either supplement the above-described strategies or are being employed by other Lido Companies, including those utilized at Enterprise. In those cases, Lido has incorporated oversight of those strategies through its Investment Committee. Lido manages each Lido client’s managed assets based on the client’s instructions as well as stated goals and objectives. Lido may utilize other independent third-party asset managers (“TPAMs”) and sub-advisors to affect other strategies on behalf of a client. Lido generally manages all client assets on a fully discretionary basis. In exercising full discretionary authority, Lido has decision-making authority to select, without first obtaining client’s authorization:
• the securities to be bought and sold;
• the amounts of securities to be transacted and whether it will be individually, or block traded;
• the broker-dealer through which transactions will be executed; and/or
• the TPAM and/or sub-advisor used to manage the client assets. Clients can impose reasonable parameters to Lido’s discretionary authority, including but not limited to, restrictions in certain companies or industry sectors or directed brokerage. Clients may also choose to instruct Lido to invest only in a specific strategy or investment offering which may not include a full asset allocation or discretionary management services. In these instances, clients are solely responsible for informing Lido in writing of these parameters, changes to these parameters, or their overall investment goals and objectives. Finally, clients may also direct Lido to execute certain trades or purchase certain investments. In these instances, clients assume full responsibility for these directed trades or investments, including any negative impact these may have on Lido’s strategies employed on their other assets. Lido cannot and does not make any assurance that client directed trades will be timely executed or executed at all.9 Lido is not responsible for any initial or ongoing due diligence on any directed investment that is not recommended by Lido. 2. Asset Allocation Services At the onset of a typical client relationship, Lido implements its integrated wealth approach and deploys its strategies through an asset allocation plan that aims to balance a client’s overall financial objectives with individual attributes 5 Hybrid offerings generally includes merger funds, long-short commodity funds, structured notes, covered options, and other hybrid mutual

funds (based on equity volatility). 6 Liquid alternative investments are investments in exclusively single-sector or commodities ETFs or alternative mutual funds. 7 Non-liquid alternative investments, which include, but are not limited to, private funds issued by affiliates and non-affiliated third parties (that are typically pooled investment vehicles that are exempt from SEC registration as securities offerings), which include, but are not limited to, hedge funds, fund of funds, real estate funds, managed futures funds, mezzanine funds, private equity funds, venture capital funds, and other types of private pooled investment vehicles, private REITs, private real estate holdings, and oil and gas limited partnerships. 8 Non-liquid fixed-income investments are defined as longer-term investments in loans secured by first trust deed mortgages, including, but not limited to, first trust deed loans, bridge loans and client-directed family mortgages. 9 In certain instances, and at its sole discretion, Lido will arrange for clients to open trading accounts at a broker-dealer/custodian on a non-discretionary basis. These non-discretionary accounts are subject to third-party fees, including, but not limited to, commissions and other custodial-related fees. These broker-dealers/custodians will as a general practice provide disclosures concerning these fees directly to clients. Clients should review this information carefully and are encouraged to discuss these fees with Lido and the broker- dealer/custodian. LIDO ADVISORS FIRM BROCHURE (PART 2A OF FORM ADV) I 2024 5 including risk tolerance, income requirements, liquidity requirements, income taxes, and investment time horizon. Lido accomplishes this by gathering pertinent information from a client during the account opening process through a Client Risk Profile, Investment Policy Statement (“IPS”), or other similar documentation. Clients may also opt for a more limited investment approach that would not necessarily include asset allocation services. Lido performs the following services in determining and maintaining the appropriate asset allocation plan for clients:
• Analysis of the client’s current financial situation and prior investment experience;
• Assistance in setting goals to determine appropriate time horizons, investment objectives, income taxes, family structure, and amounts needed to accomplish investment goals;
• Analysis of the client’s risk tolerance;
• Selection of appropriate asset classes;
• Investment selection utilizing, as appropriate, mutual funds, equity and fixed income securities, hedged equity and options, private funds, and TPAMs;
• Ongoing monitoring of fund, securities, and manager performance;
• Ongoing portfolio performance analysis; and
• Portfolio modifications and reallocation as appropriate 3. Mutual Fund Lido serves as investment advisor to the Oakhurst Strategic Defined Risk Fund (“OASDX”), a mutual fund, which seeks capital appreciation while seeking to limit short-term risk using derivatives. Please refer to the OASDX prospectus for more detailed information, a copy of which can be provided upon request. 4. TPAMs As referenced in Item 1.B.1 above, Lido has the discretion to delegate management of all or part of a client’s assets to TPAMs. Lido provides access to TPAMs through a third-party platform of approved investment managers made available by agreement between Lido and the platform provider, or through an arrangement between Lido and TPAMs. TPAMs will have discretionary authority over those assets allocated to them and they are authorized to buy, sell, and trade in securities in accordance with the client’s investment objectives, risk tolerance, and time horizon, among other factors. If and when Lido determines that a TPAM is in the client’s best interest, the client or Lido, on the client’s behalf, will enter into a separate and independent advisory relationship with that TPAM. As such, the client will incur fees separate from and in addition to any fees charged by Lido. The TPAM may invoice its fee to the client through Lido or debit the client’s custodial account directly. Lido continues to monitor TPAMs to ensure their adherence to the philosophy and investment style for which they were selected and will provide recommendations to the client accordingly. Lido will monitor investments in the TPAM accounts, but not to the degree that it does in the accounts that it directly manages. If the client has entered into a direct relationship with the TPAM, only the client can terminate that relationship. 5. Sub-Advisory Arrangements As referenced above, Lido has the discretion to enter into other sub-advisory arrangements for management of a particular style or strategy desired by and deemed suitable for clients. The sub-advisors can be non-affiliated third parties or affiliates of Lido. When engaging an affiliated sub-advisor, Lido will provide further information concerning these sub- advisors as well as the nature and scope, among other information, of its affiliation. Lido conducts due diligence on each sub-advisor, which include encompass, among other things, review of its performance returns, management team, and adherence to the guidelines and restrictions of the strategy. In its sole discretion, Lido has the authority to add, replace, or remove any sub-advisor on behalf of a client without the client’s prior consent. Lido has entered into an agreement with Spearhead Administrative Services, LLC, a registered investment adviser that acts as investment manager for an insurance company, solely in respect of one or more separate investment accounts or sub-accounts, each of which is established by the insurance company for the purpose of supporting certain benefits LIDO ADVISORS FIRM BROCHURE (PART 2A OF FORM ADV) I 2024 6 payable under one or more variable life insurance policy, variable annuity policy or other variable insurance policy that is characterized under Section 817(d) of the U.S. Internal Revenue Code of 1986, as amended, as a “variable contract” issued by the carrier to the contract owners. Lido acts as sub-advisor to Spearhead, solely in respect of the specified accounts or subaccounts, to provide research, due diligence, investment recommendations and asset allocation recommendations in accordance with the account or sub-account’s stated investment objectives and strategies. See also Item 11 (Code of Ethics, Participation or Interest in Client Transactions and Personal Trading) and Item 12 (Brokerage Practices). 6. Financial Planning Lido also offers financial planning services. These services include, but are not limited to, providing advice on the following:
• Investment portfolio analysis and asset allocation;
• Evaluation of outside investment accounts and assessment of overall financial position;
• Insurance and risk management evaluation;
• Estate and retirement planning;
• Cash flow analysis;
• Current and future income needs analysis;
• Legacy strategy;
• Tax awareness10;
• Wealth transfer and charitable giving;
• College savings; and
• Family governance and living expense considerations. To begin the process, Lido generally collects, organizes, and assesses client data including information concerning the client’s lifestyle, risk tolerance, and cash flow, as well as identification of the client’s financial concerns, goals, and objectives. Lido’s primary objective is to assist clients in developing a strategy for successfully managing income, assets, and liabilities to meet their financial goals and objectives. Lido will provide clients with a comprehensive plan and options of utilizing Lido to implement this plan. Should a client adopt Lido’s plan, Lido will advise on actual or potential conflicts of interest arising from Lido’s use of its own advisory services or strategies. Clients can accept or reject Lido’s financial plan and retain authority and discretion over all implementation decisions. Should the client proceed with Lido’s financial plan, actual or potential conflicts of interest will arise as Lido will likely utilize its own allocations, strategies, products, or services and will receive fees or other monetary benefits as a result. Lido will endeavor to address these conflicts through disclosures and other remediation efforts as the circumstances warrant. A client is under no obligation to utilize Lido’s plan or its services to implement the plan. See also