Eagle Bay is a multi-family office that offers a variety of advisory services, which include investment advisory and family office services. Prior to Eagle Bay rendering any advisory services, clients are required to enter into one or more written agreements with Eagle Bay setting forth the relevant terms and conditions of the advisory relationship (the “Wealth Management Agreement”). Eagle Bay has been an investment adviser that is majority owned by Michael Nelson since June 12, 2015. As of December 31, 2023, Eagle Bay had $886,838,673 of assets under management, of which $884,365,175 was managed on a discretionary basis and $2,473,498 was managed on a non-discretionary basis. While this brochure generally describes the business of Eagle Bay, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Eagle Bay’s behalf and is subject to the Firm’s supervision or control. Family Office Services Eagle Bay offers clients a broad range of family office services, which may include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Manager Due Diligence In performing these services, Eagle Bay 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. Eagle Bay may recommend clients engage the Firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Eagle Bay or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Eagle Bay under the 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 Eagle Bay’s recommendations and/or services. Investment Advisory Services Eagle Bay manages client investment portfolios on a discretionary or non-discretionary basis. In addition, Eagle Bay may provide clients with wealth management services which generally/may include a broad range of comprehensive family office services as well as discretionary and/or non- discretionary management of investment portfolios. Eagle Bay primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. In addition, Eagle Bay 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.,

hedge funds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage Eagle Bay to manage and/or 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, Eagle Bay 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. Eagle Bay 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. Eagle Bay 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 Eagle Bay 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 Eagle Bay 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, Eagle Bay may select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Eagle Bay 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 exposure. Eagle Bay also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Eagle Bay continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Eagle Bay seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Eagle Bay utilizes recognized consultant(s) in the field in assisting in the selection and due diligence of Independent Managers.