Kovitz is an investment adviser that provides investment management, wealth management, and financial planning services. Kovitz has over 220 employees, and we provide our services to individual and institutional clients. Our institutional clients include endowments, municipal government entities, charitable organizations, employee benefit (ERISA) plans, corporations, and other entities. We provide our services from multiple locations: our headquarters in Chicago (“Chicago Office”), and from our offices in Orange County, California (“California Office”), Madison, Wisconsin (“Madison Office”) and Southfield, Michigan (“Telemus Capital”) and Deerfield, Illinois and Milwaukee, Wisconsin (“Strategic Wealth Partners”). Kovitz was created in December of 2015 in response to being acquired by Focus. From October 1, 2003 to December 31, 2015, the Firm was defined as Kovitz Investment Group, LLC. Effective January 1, 2016, Kovitz Investment Group, LLC underwent an organizational change and all persons responsible for portfolio management became employees of Kovitz. From January 1, 1997 to September 30, 2003, all persons responsible for portfolio management comprised the Kovitz Group, an independent division of Rothschild Investment Corp (Rothschild). Effective March 1, 2024, Kovitz completed the acquisition of assets of, and combination with Telemus Capital, LLC. Telemus Capital is now part of Kovitz and will be doing business as Telemus Capital within Kovitz’s registered investment adviser. Effective May 1, 2024, Kovitz completed the acquisition of assets of, and combination with Strategic Wealth Partners Group, LLC. Strategic Wealth Partners, (“SWP”) is now part of Kovitz and will be doing business as Strategic Wealth Partners within Kovitz’s registered investment adviser. As of March 1, 2024, Kovitz has approximately $11.2 billion of regulatory assets under management. This is composed of approximately $10.6 billion of assets managed on a discretionary basis and approximately $649 million on a non- discretionary basis. Focus Financial Partners Kovitz is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Kovitz is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Kovitz is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Kovitz. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. INVESTMENT MANAGEMENT – GENERAL Our main business is providing discretionary investment advice to individuals and institutions in separate accounts (further described below under the section entitled “Item 16. Investment Discretion”). We primarily invest each of our client’s portfolios in equities (stocks) and/or fixed income (bond) securities. Each of our clients has his/her own account, and the equities and bonds in the account are usually individual securities. KOVITZ FORM ADV PART 2A |5 We first consult with our clients to understand their financial situation, such as their objectives for asset growth, income and liquidity, principal protection, risk tolerance, and tax minimization. Next, based on the above information, we recommend an initial target asset allocation for each client, generally meaning the percentage of stocks and bonds to be put in the portfolio. After working with the client to select an appropriate asset allocation, the Kovitz Chicago Office generally implements it across the client relationship, or all of the client’s accounts (“allocation group”), to the extent feasible. Generally, Kovitz Chicago, Telemus Capital and Strategic Wealth Partners manages an asset allocation at the allocation group level, which means there will be variation as to asset allocation within a specific underlying account. In addition, if a client adds an account to their relationship with us, we will add the account to the existing allocation group, with the agreed-upon asset allocation, unless directed otherwise by the client. The Kovitz Madison and California Offices generally manage asset allocation at the account level. We meet with our clients to understand their needs, circumstances and objectives, work with our clients’ other advisers, and rebalance, and periodically review the client’s asset allocation. We will consider the client’s individual situation and the nature, position size, and suitability of specific securities when reviewing and making purchase and sale decisions for each of our clients. In this manner, we tailor our investment management services to the needs of our clients. Our clients may restrict us in the management of their accounts, such as the amount, type, or identity of stocks or bonds to buy or sell, as long as they are reasonable, consistent with our professional responsibility and investment philosophy, and allow us to substantially implement our investment strategies. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Additionally, Kovitz is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan participants. Kovitz is also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants (collectively, “Retirement Account Clients”). As such, Kovitz is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). INVESTMENT MANAGEMENT – CALIFORNIA OFFICE Kovitz also offers discretionary investment advice on individual securities to clients by way of its California office through various strategies in separately managed accounts. The California Office’s philosophy includes primarily investing in equity securities that are considered out-of-favor and undervalued by the investing public. The philosophy also includes holding them until they have reached what their investment team believes is a reasonable fair value, or until the team finds equity candidates with what it believes are more attractive risk/reward attributes, or the particular equity’s risk/reward profile does not justify continued ownership. Kovitz California generally implements it strategy on an account basis instead of across all of the client’s accounts. Additional details about the California Office’s strategies are further described in the sections entitled, “Equities – California Office,” “ETFs – California Office,” and “The Prudent Speculator – California Office.” KOVITZ FORM ADV PART 2A |6 INVESTMENT MANAGEMENT – MADISON OFFICE In addition, Kovitz offers discretionary investment advice through various strategies in separately managed accounts via its Madison Office. The Madison Office’s philosophy includes investing primarily in equity and fixed income securities, along with exchange-traded funds (“ETFs”) and mutual funds. Client accounts in these strategies can solely hold equities, solely fixed income securities, or a combination of several security types. The philosophy of the Madison Office is suited for those who share their belief in long-term investment strategies. Kovitz Madison generally implements it strategy on an account basis instead of across all of the client’s accounts. Additional details about strategies offered by the Madison Office are further described in the sections entitled, “Equities – Madison Office” and “Fixed Income Securities – Madison Office.” INVESTMENT MANAGEMENT – TELEMUS CAPITAL Telemus Capital will consult with our clients to understand their financial situation, such as their objectives for asset growth, income and liquidity, principal protection, risk tolerance, and tax minimization. Based on the results of the client discussion(s) and the information provided by the client, we prepare a Financial Life Proposal for the client which includes the agreed upon investment strategy. For clients using the Envestnet program (described below), we prepare and review with the client a customized Statement of Investment Selection (“SIS”). The SIS incorporates an investment profile summary, summarizes the information the client has provided us and makes recommendations for the client’s portfolio based on the information provided. Using tools provided by Envestnet, we may recommend that the client’s portfolio be allocated among various investment managers and/or products. After reviewing the client’s final investment strategy or SIS (in the case of clients using the Envestnet program), the client enters into an investment advisory agreement (“Client Agreement”) with Telemus Capital. The Client Agreement discusses the services to be provided to the client and other applicable terms and conditions. For most client accounts, Telemus Capital constructs client portfolios generally in accordance with our traditional model strategies: Income Only, Capital Preservation, Conservative, Moderate, Balanced, Aggressive, Ultra Aggressive and Growth Only. Client portfolios are managed in accordance with the model strategy most appropriate for the client’s risk profile. Each model strategy can allocate across as many as five sleeves: Growth, Diversifier, Income (either with taxable or tax- exempt bonds), Private Investments and Cash. Allocations to each sleeve are made in differing percentages depending on the risk profile of each model. All of the model strategies include some combination of individual equities, individual bonds, mutual funds, ETFs, private funds and potentially other investment products. For accounts not deemed large enough for the traditional models or clients seeking a passively managed portfolio, Telemus Capital also constructs client portfolios in accordance with the following model strategies: Ultra-Conservative, Conservative, Moderate, Balanced, Aggressive and Ultra-Aggressive. Client portfolios are managed in accordance with the model strategy most suitable for the client’s risk profile. Each model strategy has three sleeves: Growth, Income and Cash. Allocations to each sleeve are made in differing percentages to each model strategy depending on the risk profile of the strategy. All of these model strategies are constructed with passive ETFs. Clients should know that their assets in each model strategy are likely to be managed in a manner similar to other clients having similar investment objectives and risk tolerance. The implementation of a model strategy may vary depending on a client’s preferences for separately managed accounts, current income, liquidity constrains, taxes or environmental/social/governance concerns. We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). KOVITZ FORM ADV PART 2A |7 INVESTMENT MANAGEMENT – STRATEGIC WEALTH PARTNERS We provide personalized and holistic wealth and investment management services to clients on a discretionary and non- discretionary basis. As detailed in Item 8, we typically allocate clients' investment management assets among professionally managed investments such as Mutual Funds, Exchange- Traded Funds ("ETFs"), Structured Notes, Interval Funds, External Managers, Private Collective Investment Vehicles, Treasuries Notes and other securities we believe are appropriate. Additionally, we may recommend that clients who are accredited investors or qualified purchasers as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which may include debt, equity, and/or pooled investment vehicles when consistent with the client’s investment objectives. The Firm renders services to certain clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that the client's primary Custodian may not hold. In so doing, SWP either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or Custodian designated by the product. The Firm tailors its advisory services to the individual needs of clients. SWP consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon, and other factors that may impact their investment needs. SWP ensures that clients' investments are suitable for their investment needs, goals, objectives, and risk tolerance. Clients are advised to promptly notify the Firm if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon the Firm's management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in SWP's sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. For Participant Directed plans, SWP, in its fiduciary capacity, will provide the client non-discretionary investment advice about asset classes and investment options for the Plan. SWP may also provide non-fiduciary services to the plan, including client education, group enrollment, and participant education. For Pooled Plans, in its fiduciary capacity under Section 3(38) of ERISA, investment decisions are made by SWP in its discretionary capacity. In addition, SWP may assist in the development of an investment policy statement. EQUITIES – GENERAL For the equities portion of our clients’ portfolios, we seek to maximize total return through a combination of long-term capital appreciation and the receipt of dividends and income while maintaining an emphasis on the preservation of capital. We approach buying equities for our clients as if we are part owners of businesses, not traders of stocks. We look to maximize the investment return we achieve given the investment risk we take. We view risk as the odds of a permanent loss of capital and not volatility of returns. We believe purchasing stock in competitively advantaged and financially strong companies at prices substantially less than our assessment of their intrinsic (business) value is the best way to preserve client capital over long periods of time. Generally, the companies we invest in are usually larger capitalization companies. EQUITIES – CALIFORNIA OFFICE The equity strategies (the ones that are currently “marketed” to current and prospective clients of the California Office) include the following: KOVITZ FORM ADV PART 2A |8 The Kovitz ValuePlus strategy (also known as “Kovitz Dividend Value,” which combined the strategies formerly known as “Al Frank Value” and “Al Frank Select Value”) includes both dividend and non-dividend paying stocks and seeks broad diversification through exposure to a significant number of major market sectors and industry groups. For client accounts in this strategy, the investment team in the California Office typically builds portfolios containing 70 – 90 stocks. The Kovitz Focused ValuePlus strategy (formerly known as “Al Frank Select Focused Value”) seeks long-term capital appreciation by investing in a more concentrated portfolio of stocks across major market sectors and industry groups. For client accounts in this strategy, the California Office investment team typically builds portfolios containing roughly 30 – 40 stocks. The Kovitz Dividend Income strategy (which combined the strategies formerly known as “Al Frank Dividend Value” and “Al Frank Select Dividend Value”) includes dividend paying stocks, and seeks broad diversification through exposure to a significant number of major market sectors and industry groups. For client accounts in this strategy, the California Office investment team typically builds portfolios of equally weighted positions containing 60 – 80 stocks. The Kovitz Focused Dividend strategy (formerly known as “Al Frank Select Focused Dividend”) seeks long-term capital appreciation and dividend income through mostly dividend-paying stocks, and seeks broad diversification through exposure to major market sectors and industry groups. For client accounts in this strategy, the California Office investment team typically builds portfolios that contain roughly 30 – 40 stocks. The Kovitz Small-Mid Dividend Value strategy (formerly known as “Al Frank Select Small-Mid Dividend Value”) includes primarily micro, small, and mid-cap dividend paying stocks, and seeks broad diversification to a significant number of major market sectors and industry groups, although market appreciation sometimes results in these stocks moving into what is known as the “large-cap” category. For client accounts in this strategy, the investment team in the California Office typically builds portfolios containing 70 to 90 stocks. The Prudent Speculator strategy generally mirrors the TPS portfolio (“TPS Strategy”), the basis for “The Prudent Speculator” newsletter (which is further described below). The TPS Strategy includes both dividend and non- dividend paying stocks and seeks broad diversification through exposure to a significant number of major market sectors and industry groups. For clients in the TPS Strategy, the investment team in the California Office typically builds portfolios that initially contain 70 to 90 positions. EQUITIES – MADISON OFFICE The primary goal of the equity strategies managed by the Madison Office (whether as part of stock-only portfolio, or as part of a “balanced” portfolio containing a mix of equities and bonds) is to provide performance returns from a diversified portfolio of stocks that exceed appropriate benchmarks, such as the S&P 500 Index. The Madison Office’s equity strategies typically include a mix of small-, mid-, and large-capitalization domestic and international stocks. The investment team in the Madison Office uses internal and external research to help identify companies where the current market prices do not correctly reflect the team’s opinion of the underlying value or future growth potential. The team’s decisions to buy or sell securities are based on expected return, as well as the potential impact of the transactions on the applicable clients’ overall diversification. For certain client account groups, the team also uses cash (and/or cash equivalents) as a way to help reduce market risk at times when it believes the overall stock market is unattractive on a risk/return basis, or to enhance the client’s portfolio yield and/or liquidity. KOVITZ FORM ADV PART 2A |9 EQUITIES – TELEMUS CAPITAL The equity strategies (the ones that are currently “marketed” to current and prospective clients of Telemus Capital) include the following: Core Equity: Actively managed core equity strategy that focuses on large-cap companies with demonstrated consistent, above-average earnings growth and reasonable valuations. It is managed relative to the Russell 1000 and/or S&P 500 Indices as benchmarks. Evercore Wealth Management LLC currently serves as sub-advisor for this strategy. Taurus: Actively managed growth strategy focusing on above-average growth businesses that are poised to benefit from secular growth trends. The process utilizes a proprietary screen to identify attractive securities alongside fundamental and technical analysis. Aware: Actively managed domestic equity portfolio focused on making investments in businesses that meet strict environmental, social and governance (ESG) criteria. High and Rising Dividend: Equity strategy which seeks to invest in equity securities of companies that pay relatively high dividends as measured by yield. Stability and/or growth of dividends and dividend yield may also be considered by the manager. The strategy invests across a broad range of market capitalizations. It is primarily designed for taxable investors seeking current income and/or who can benefit from the lower federal income tax rates applicable to dividends and/or long-term capital gains. The strategy may also be appropriate for taxable or tax-exempt investors seeking a different and complimentary income stream, the principal of which can fluctuate greatly. Finally, investors may use this strategy to diversify their equity allocation. Investments are diversified across sections and industries in an effort to reduce the risk of concentrating investments only in industries with the highest dividend yields. FIXED INCOME SECURITIES – GENERAL For the bond portion of our clients’ portfolios, we focus on diligent execution and high credit quality. We take into consideration our client’s tax situation, the type of issuer and bond, and general market conditions when we construct bond portfolios for our clients. Depending on the client’s needs, market conditions, and pricing, we typically purchase the following types of bonds for our clients: Taxable, tax-free, and alternative minimum tax (AMT) municipal bonds; Municipal bonds; Corporate bonds; Mortgage-Backed Securities; and U.S. Treasury and government agency bonds. Our goal is to capture excess yield without incurring additional risk. We primarily try to accomplish this by patiently bidding on bonds owned by third party bond sellers, by finding bonds with perceived complexity and liquidity risks, and by our willingness to buy odd (smaller) lots of bonds. The demand for these kinds of bonds is typically lower, and therefore we attempt to buy them at lower prices (and higher yields) for our clients. KOVITZ FORM ADV PART 2A |10 The firm primarily uses a network of third-party dealers and electronic trading platforms to help construct fixed income portfolios for clients. Please refer to the “Directed Brokerage” section under “Item 12. Brokerage Practices” for examples of these brokers. We generally buy bonds with the intent to hold to maturity, and therefore we are less concerned about interim price changes. We do not keep bonds in an inventory for later sale to our clients. We buy bonds for direct allocation to specific client accounts based on the specific client’s asset allocation and circumstances. Depending on our specific client’s investment objective, we will typically build a bond ladder of individual bonds maturing in different years in order to provide liquidity, an income stream, and to help guard against interest rate and credit risk. FIXED INCOME SECURITIES – MADISON OFFICE The primary goal of the fixed income strategy of the Madison Office (whether as part of a bond-only portfolio, or a balanced portfolio containing a mix of equities and bonds) is to provide performance returns from a diversified portfolio of bonds that exceed industry-recognized benchmarks, such as the Barclays Intermediate Government/Credit Index. The fixed income strategy typically includes a mix of U.S. Treasury and government agency bonds; investment and below-investment grade corporate bonds; convertible bonds; municipal bonds; mutual funds; and fixed income ETFs. The Madison Office investment team evaluates and selects fixed income securities based on its assumptions about interest rates, the treasury yield curve, company-specific risk, and other variables that will impact the relative performance of the security. Similar to what it does for its equity (and balanced) strategies for certain client account groups, the team uses cash (and/or cash equivalents) when it believes that the fixed income market is unattractive on a risk/return basis or to enhance the client’s portfolio yield and/or liquidity. FIXED INCOME SECURITIES – TELEMUS CAPITAL The fixed income strategies (the ones that are currently “marketed” to current and prospective clients of Telemus Capital) include the following: Investment Grade Taxable Fixed Income: Actively managed intermediate taxable bond portfolio managed relative to the Bank of America Merrill Lynch 1-10 Year US Corporate & Government Index as its benchmark. High Yield Taxable Fixed Income: Actively managed fixed income portfolio that focuses exclusively on the highest quality (BB) component of the high yield universe. The portfolio is managed relative to the Bank of America Merrill Lynch 1-10 Year BB Cash Pay High Yield Index as its benchmark. Blended Taxable Fixed Income: Actively managed fixed income portfolio that combines Telemus Capital’s investment grade capability with its high yield (BB) capability. The portfolio is managed relative to a custom blended benchmark comprised of 50% corporate/government intermediate investment grade bonds (as identified in the Bank of America Merrill Lynch 1-10 Year US Corporate & Government Index) and 50% intermediate BB rated bonds (as identified in the Bank of America Merrill Lynch 1-10 Year BB Cash Pay High Yield Index). Treasury Bond Ladder: Actively managed strategy that invests in Treasury bonds 1-10 years in maturity. KOVITZ FORM ADV PART 2A |11 Tax-Exempt Fixed Income: Actively managed strategy that focuses on investment grade, short-to-intermediate maturity municipal bonds. The strategy is customized to maximize the after-tax returns for each individual client. OTHER TYPES OF SECURITIES OPTIONS We use option transactions in conjunction with our day-to-day management of clients’ equity investments. We primarily do this by selling covered calls. Our clients own the stock and, in return for a premium, we sell to a third party the right to buy the stock at a certain price by a certain date. We usually do this for tax reasons to extend the holding period so our clients can get more favorable long-term capital gains tax treatment. When option prices are volatile, we have also sold covered calls to generate

income for clients and to manage their sector exposures. Typically, we will sell “at the money” calls (where the call strike price is near the underlying stock’s market price) in order to maximize the premium that the client receives. We also use other option strategies as a way for clients to earn income while waiting to invest their assets in our primary equity strategy. We accomplish this by, for example, buying or selling options on index-tracking ETFs, or by selling puts on our equity recommendations. The goal of these strategies is to supplement the firm’s primary equity investment strategies as a way to enhance client returns. MUTUAL FUNDS Open-End Mutual Funds Occasionally, we recommend investments in no-load, open-end mutual funds instead of individual equity or fixed income securities. We believe this is appropriate for diversification in smaller accounts below our recommended investment minimums (described below in the section entitled “Types of Clients”) or to gain access to sectors outside of our core investment strategies, and usually at a client’s request. Al Frank Fund We also manage an affiliated mutual fund, the Al Frank Fund (ticker: VALAX). The Al Frank Fund is an advisory client of Kovitz, and Kovitz generally intends to manage the Al Frank Fund according to the same strategy as that of its separate (equity) account clients that are managed by the investment team in the California Office. Depending on the prospective client or client’s investment objectives and risk tolerance, the California Office generally recommends the Al Frank Fund for those clients who have assets below applicable investment minimums (refer to the section below entitled “Types of Clients”), or otherwise for clients and prospective clients who we believe would be better served by the diversification that we intend for the Al Frank Fund to provide. Please refer to the Al Frank Fund prospectus for more information, or the website (www.alfrankfunds.com). Absolute Capital Opportunities Fund In addition to the mutual funds noted above, we are the sole sub-adviser of an affiliated mutual fund, the Absolute Capital Opportunities Fund (ticker: CAPOX). The primary adviser of CAPOX has hired us to manage the fund consistent with, and according to the same long/short equity strategy as our affiliated hedge funds (which we further describe below). Depending on the prospective client or client’s investment objectives and risk tolerance, we also recommend CAPOX to our clients as a way to diversify a traditional portfolio of equity and bond investments. Our goal is for CAPOX investors to achieve returns that do not always directly relate to those in the equity markets, and to preserve capital significantly better than “unhedged” equity investments. We believe CAPOX is suitable for advisory clients who have assets below our “separate account” or hedge fund investment minimums, and for those who desire daily liquidity, as it is a publicly registered mutual KOVITZ FORM ADV PART 2A |12 fund. Please refer to the CAPOX prospectus for more information, or the CAPOX website (www.absoluteadvisers.com/absolute-capital-opportunities-fund/fund-overview). ETFS – GENERAL Similar to our approach with open-end mutual funds, we occasionally recommend investments in ETFs instead of individual equity or fixed income securities. We believe this is appropriate for diversification in smaller accounts below our recommended investment minimums, to gain access to sectors outside of our core investment strategies, or at a client’s request. Additionally, we leverage ETFs as a strategy where we use passively managed indexes by using various index ETFs to give our clients direct exposure to the various markets. In addition, we use active ETF’s, such as EQTY, for a portion of a client’s equity portfolio. Kovitz Core Equity ETF We manage an affiliated ETF, the Kovitz Core Equity ETF (ticker: EQTY) (“EQTY”). EQTY is an advisory client of Kovitz, and Kovitz generally intends to manage EQTY according to the same strategy as that of its separate (equity) account clients that are managed by the investment team in the Chicago Office. Depending on the prospective client or client’s investment objectives and risk tolerance, the Chicago Office generally recommends EQTY for those advisory clients who have assets below our investment minimums (refer to the section below entitled “Types of Clients”), or otherwise for clients and prospective clients who we believe would be better served by the diversification that we intend for EQTY to provide. Please refer to the EQTY prospectus for more information, or the EQTY website (www.Kovitz.com/eqty). ETFS – CALIFORNIA OFFICE Aside from our general use of ETFs in the context described above, the California Office recommends strategies that invest in portfolios of ETFs, with the goal of outperforming applicable benchmarks on a risk-adjusted basis through diversification; active management; style integrity; minimized security selection risk; trading; and cost efficiency. The California Office offers the following ETF strategy: Kovitz Global Value (also known as Dynamic Portfolio Series (“DPS”)) The Dynamic Portfolio Series seeks opportunities in U.S. equities, developed international equities, emerging and frontier market equities, commodities, REITs and global fixed income. The family of portfolios seek to provide long-term absolute return through a combination of enhanced diversification and tactical management of portfolio-level exposures to valuation and behavioral factors over time. The valuation factors ensure the portfolio maintains a preference to exposures with strong fundamentals, while the behavioral factor seeks to capitalize on near-term opportunities. The country rotation segment of the strategy seeks to provide complimentary returns through enhanced diversification at the individual country equity market level. In strategies with lower risk tolerance, a Fixed Income portion acts as a ballast during challenging market conditions, while maximizing income for a set level of risk. ETFS – MADISON OFFICE The Madison Office’s strategies occasionally use ETFs with the goal of increasing diversification and enhancing returns. The investment team believes certain ETFs can provide client portfolios with exposure to investment opportunities that fall outside the team’s traditional research universe, such as market segments (market capitalization or style), international, alternative investment, or sectors where the team believes that individual stock selection does not adequately reflect the desired exposure for the client. KOVITZ FORM ADV PART 2A |13 ETFS – HEDGED FUNDS AND RELATED ACCOUNTS In managing our affiliated hedge funds and certain separately managed accounts (described below under “Hedge Funds”), we take short positions in ETFs that are sometimes held as long positions in individual advisory client accounts. We acknowledge the potential conflict of interest in making such recommendations. However, we believe that it is not inconsistent or disadvantageous to a particular client to use ETFs in the hedge funds as part of an overall hedging strategy (and not necessarily as an assertion of our view on the sector covered by the ETF), and also as a way to gain exposure in a diversified manner to that same sector for a particular advisory client. We have considered that it is unlikely that our trading activities would impact the price of ETFs, and that their use for individual advisory clients is not a significant part of the firm’s overall assets under management. COLLATERALIZED MORTGAGE OBLIGATIONS If suitable for a particular client, we also recommend investments in collateralized mortgage obligations (CMOs), also known as mortgage-backed securities (MBS). This recommendation depends on the client’s investment objectives and risk tolerance, and is part of the client’s overall asset allocation. HEDGE FUNDS AND OTHER PRIVATE PLACEMENTS Kovitz manages hedge funds in which clients and others are solicited to invest. All such funds are limited to accredited investors. The hedge funds generally invest in equities and options. Kovitz also provides services to, or certain of its employees are otherwise involved in several private real estate funds in which clients and others have been solicited to invest. These funds are limited to accredited investors, and their objectives are to invest in properties across the real estate sector, including industrial, commercial, and residential. In addition, certain of Kovitz’s executive officers own a separate company that sponsors and manages private equity funds. All such funds are limited to accredited investors. The private equity funds’ primary investment objectives are to acquire controlling interests in existing companies and to make other investments. Kovitz is the investment manager to the Telemus Decorrelation Opportunity Fund, LP (the “TDOF Fund”), and its affiliate, Telemus Decorrelation Opportunity GP, LLC, is the General Partner of the Fund. The TDOF Fund, which is a fund of funds, is a multi-strategy, privately offered investment vehicle that invests in a diversified portfolio of investments that seeks to provide low and non-correlated returns relative to the broader equity and fixed income markets. The underlying investment strategies include, but are not limited to, insurance-linked securities, longevity-contingent assets, real estate credit, alternative lending, and other assets that generally have low or non-correlated returns with traditional financial markets. The TDOF Fund is closed to new investors and is in the process of being dissolved. Kovitz’s affiliate, Telemus Life Science Real Estate Fund Manager, LLC, is the Manager of the Telemus Life Science Real Estate Fund, LLC (the “TLSRE Fund”). The TLSRE Fund is a privately offered investment vehicle that was created for the purpose of investing in IQHQ, Inc., a privately traded REIT formed to acquire, develop and redevelop real estate for life sciences tenants. WRAP AND UNIFIED MANAGED ACCOUNT PROGRAMS We also participate in several wrap, Unified Managed Account (UMA), and other “turnkey” asset management programs (TAMPs), although we do not “sponsor” any such programs. In these cases, the sponsors of such programs typically have contracts directly with their clients to perform various types of investment management services. For UMA programs, the sponsors hire us to deliver “model” portfolios to them. We generally apply the same equity investment philosophy and strategy for clients of wrap and UMA programs as we do for our own separate account clients, depending upon the strategy for which they’ve hired us, and depending upon any restrictions, limitations, or specific directions that the sponsors or their KOVITZ FORM ADV PART 2A |14 clients give to us. The sponsors of the wrap and UMA programs generally charge their clients an aggregated or “all-inclusive” fee, and we receive a portion of those fees. Kovitz, primarily Telemus Capital, also has relationships with external providers of investment management, research and due diligence services. One such service provider is Envestnet1, a registered investment adviser that provides an asset management platform and related technology, as well as operational and administrative support services. TC uses some of the services provided by Envestnet, including the Unified Managed Account Program (the “UMA program”) and the Separate Managed Accounts Program (the “SMA program”). Through the UMA program Telemus Capital constructs a single client portfolio comprised of various investment vehicles, typically third-party managers. Through the SMA program Telemus Capital will select third party managers which are appropriate to manage the client’s assets. In both programs, the client grants Kovitz, Telemus Capital, with discretion to make changes to the managers and/or investments if Telemus Capital determines such a change is in the client’s best interest. Factors considered in making this determination include account size, risk tolerance, the opinion of each client, the investment philosophy of the third-party manager, and the client’s investment objectives. Kovitz, Telemus Capital, will have full discretionary authority to invest and reinvest client assets and retain third party asset managers who, in turn, have full discretionary authority to invest and reinvest client assets, subject to reasonable restrictions imposed by the client. THE PRUDENT SPECULATOR – CALIFORNIA OFFICE Kovitz publishes “The Prudent Speculator” (“TPS”), an investment newsletter which is written by the investment team in the California Office, and charges an annual subscription fee. TPS provides frequent commentary about the financial markets, macro-economic trends, and individual equities to subscribers. TPS also issues commentaries centered around equity recommendations, provides “sales alerts” when the TPS “newsletter portfolios” sell certain equities, and provides subscribers access to holdings reports. The holdings report allows subscribers to “mirror” the activities and holdings of their own personal securities accounts to TPS recommendations if they wish. Separate account clients in the firm’s California Office receive a complimentary subscription to TPS. FINANCIAL PLANNING SERVICES Kovitz also provides financial planning services (Planning Services) to certain investment management clients. The Planning Services include the following: analyses regarding retirement cash flows; goal identification and funding; Monte Carlo simulations; education funding; estate planning; tax planning; and charitable giving. Kovitz determines client eligibility for Planning Services on a case-by-case basis. Kovitz will consider the size of the client relationship and whether the client uses other financial advisers in determining whether to offer Planning Services. Kovitz generally does not charge fees for Planning Services in addition to the fees it charges for investment management services. Kovitz does offer financial planning and consulting services to clients who seek more complex or specific services on a standalone basis. The scope of Planning Services is agreed upon by Kovitz and the client, although Kovitz and its clients typically do not execute formal, written “agreements” in this context, as Kovitz provides the services to complement its day-to-day, ongoing investment management services. Kovitz acknowledges that if it provides Planning Services and investment management services to a particular client, there is a potential conflict of interest in making and implementing planning and investment recommendations to the client. The conflict is that the planner is a Kovitz employee and will have an incentive to choose to use or recommend Kovitz as investment manager. We believe that the conflict is addressed by the aligned long-time 1 We currently use the services of certain sub-advisors, including those of Envestnet Asset Management, Inc., Evercore Wealth Management LLC, Mar Vista Investment Partners, LLC, Aristotle Capital Management, LLC and SpiderRock Advisors, LLC. KOVITZ FORM ADV PART 2A |15 horizon of the client, the Kovitz planner, the Kovitz investment professionals, and by the fact that the Kovitz employees are not compensated in a manner that will incentivize inconsistent or short-term recommendations. Additionally, clients are under no obligation to act upon any of the recommendations made by Kovitz. Kovitz uses a combination of its Certified Financial Planner™ (CFP®) Professionals, non-CFP Professionals, and certified public accountants (CPAs) in the process of gathering and analyzing client information, in providing recommendations to the client, and in providing Planning Services. RETIREMENT PLAN REVIEW SERVICES Kovitz provides retirement plan advisory services for its clients, which provides clients the opportunity to have Kovitz review and consult on the client’s assets invested in her or his employer’s retirement plan. This provides clients with a consolidated view of their retirement assets. Kovitz and Sentinel Pension Advisors, LLC (“SPA”) have an agreement in place whereby Kovitz, primarily Telemus Capital, serves as a subadvisor to SPA for certain client retirement plans. This arrangement is more fully described in Item 10. Kovitz also offers the following non-fiduciary retirement plan services. Kovitz assists in the education of retirement plan participants about general investment information and the investment alternatives available to them under their plan. Clients understand that Kovitz’s assistance in education of plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Kovitz’s advisors are not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) when offering such educational services to plan participants. FAMILY OFFICE SERVICES In addition to Planning Services, Kovitz offers “Family Office Services”, also called Virtual Family CFO Services in some instances, to certain investment management clients. The Family Office Services include the following: comprehensive reviews and monitoring of clients’ investment assets, including investment strategies and assets that are not directly managed by Kovitz; tax planning and services; family succession planning and education; bookkeeping; insurance advice; invoice management; administrative services and bill paying services, among other things. Kovitz develops customized, detailed reports that provide meaningful information to help families better understand their overall financial picture. Kovitz determines eligibility for Family Office Services on a case-by-case basis. Kovitz typically charges fixed, hourly, or “project-based” fees for Family Office Services, depending on the nature of services provided. These fees may or may not separate from the firm’s standard “asset-based” fees that it charges for ongoing investment management. The exact fee structure is laid out in an engagement letter executed by the client. Kovitz uses a combination of its Certified Financial Planner™ (CFP®) Professionals, non-CFP Professionals, and CPAs in the process of providing Family Office Services to clients. CORPORATE EXECUTIVE SERVICES Kovitz, and primarily Telemus Capital, provides a suite of services referred to as “Corporate Executive Services.” These include concierge-like advisory services to senior corporate executives. These services, which in some cases will be in concert with third party services providers, including advisory services related to the following:  Compensation and Benefits.  Estate Planning and Wealth Transfer.  Risk Management and Insurance.  Tax Planning and Return Preparation. KOVITZ FORM ADV PART 2A |16  Retirement Planning.  Investment Planning. Corporate Executive Services is provided separately from the Investment Management services noted above and does not automatically include those investment management services noted. TELEMUS CAPITAL TAX CONCIERGE Telemus Capital’s Tax Concierge service assists clients with their tax return preparation requirements. If a client needs a tax preparer to complete his/her returns, Telemus Capital will make an introduction to a qualified CPA. If the client engages the CPA, Telemus will receive a referral fee from the CPA which is disclosed to the client. For clients using this service, Telemus Capital will help in the compilation of source documents and other information needed to complete the client’s return(s). NON-DISCRETIONARY ADVISORY SERVICES Kovitz also provides personalized investment management services on a non-discretionary basis at a client’s request. This typically involves selecting or making recommendations as to specific securities or other investments the client’s account(s) should purchase or sell based on the client’s needs and objectives, however, the client must approve the recommendations before the trade is placed. As noted above, investments by clients in affiliated private funds will be on a non-discretionary basis. Kovitz also provides fee-based wealth management services, including estate tax, social security, education expense planning and asset allocation, as well as other financial planning services to its clients on a non-discretionary basis. In addition to the non-discretionary investment management services described above, Telemus Capital also offers other non-discretionary advisory services. Clients who utilize our discretionary advisory services may, as an accommodation, also be permitted to establish non-discretionary advisory accounts in which all securities transactions are client-directed. For these accommodation accounts, Telemus Capital generally charges an annual fee of 20 basis points based on the average daily balance of the account market values for the 12-month period being billed. These assets are not included in the calculation of Kovitz’s regulatory assets under management. Additionally, certain accounts hold assets which the client has directed Telemus Capital to hold for tax or other purposes. Telemus Capital provides ongoing and continuous supervision of these client assets. These assets are included in the calculation of Kovitz’s non-discretionary regulatory assets under management. THIRD-PARTY MANAGERS Kovitz will leverage the use of unaffiliated third-party managers in some situations. Kovitz uses these managers for their expertise and/or services to manage a portion of the client’s assets. Kovitz will use outside managers for clients that are looking for active management and exposure to a wide array of asset classes. Kovitz may recommend to client, or engage on client’s behalf, one or more third-party managers to provide access to these different strategies and/or asset classes. The selection or replacement of any third-party manager will be based on Advisor’s discretion or by client’s acceptance, depending on outside manager’s structure. These third-party managers will have discretion over the assets allocated to them and Kovitz will have no ability to affect the trading decisions of said manager. For certain relationships, clients will receive the disclosure Brochure of the unaffiliated third-party manager. These managers may impose more restrictive account requirements and varying trading and billing practices than the Firm. In KOVITZ FORM ADV PART 2A |17 such instances, Kovitz will alter its corresponding account requirements and/or billing practices to accommodate those of the third-party manager. It is important for clients to read the disclosure Brochures of unaffiliated third-party managers. Kovitz will evaluate the third-party manager initially and on an ongoing basis to confirm whether the manager is suitable for Kovitz clients. Kovitz will review, among other things, the manager’s performance and management, background, specialized knowledge, expertise investment objective, and fees. In these instances, client pays Kovitz’s advisory fee in addition to the fee charged by the outside manager for the assets allocated to the outside manager. This is a conflict as client could invest directly with the outside manager without having to pay Kovitz’s advisory fee. Kovitz reduces this conflict by adding value to the outside manager relationship by performing initial due diligence on the manager and ongoing monitoring of the manager and their performance. BUSINESS RELATIONSHIPS Kovitz has a business arrangement with Institutional and Family Asset Management, LLC (“IFAM”) under which Kovitz refers certain retirement plan clients to IFAM. Kovitz is an affiliate of IFAM by virtue of being under common control with it, through Focus LLC. Please see Items 5, 10 and 14 of this Brochure for further details. Kovitz also has a business arrangement with Dorchester Wealth Management Company (“D9rchester”) under which Kovitz refers certain clients to Dorchester. Kovitz is an affiliate of Dorchester by virtue of being under common control with it, through Focus LLC. Please see Items 5, 10 and 14 of this Brochure for further details. Kovitz also has a business arrangement with Relative Value Partners, LLC (“RVP”) under which Kovitz refers certain clients to RVP. Kovitz is an affiliate of RVP by virtue of being under common control with it, through Focus LLC. Please see Items 5, 10 and 14 of this Brochure for further details. Kovitz has a business arrangement with Ancora Alternatives LLC (“Ancora Alternatives”) which is an indirect, wholly owned subsidiary of Focus LLC. The arrangement allows certain clients to have the option of investing in certain private investment vehicles managed by Ancora Alternatives. Kovitz is an affiliate of Ancora Alternatives by virtue of being under common control with it. Please see Items 5, 10, and 11 of this Brochure for further details. Kovitz has a business arrangement with Origin Credit Advisers, LLC (“OCA”), who is an indirect, wholly-owned subsidiary of Focus LLC, under which certain clients of Kovitz have the option of investing in certain private investment vehicles managed by OCA. Kovitz is an affiliate of OCA by virtue of being under common control with it. Please see Items 5, 10, and 11 of this Brochure for further details. Finally, we have a business arrangement with a subsidiary or subsidiaries of Origin Investments Group, LLC (“Origin”), who are each an indirect, wholly-owned subsidiary of Focus LLC, under which certain clients of Kovitz have the option of investing in certain private investment vehicles managed by Origin. Kovitz is an affiliate of Origin by virtue of being under common control with it. Please see Items 5, 10, and 11 of this Brochure for further details. UPTIQ TREASURY & CREDIT SOLUTIONS, LLC (“UPTIQ”) We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. KOVITZ FORM ADV PART 2A |18 FOCUS RISK SOLUTIONS, LLC (“FRS”) We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information. MY PERSONAL BOOKKEEPER (“MPB”) Kovitz, through SWP, has implemented a line of business called My Personal Bookkeeper (“MPB”) which provides bill payment, tax organization, insurance claim management and household budgeting. Although MPB is not part of Kovitz’s investment advisory services, SWP may recommend use of MPB for its clients when deemed appropriate. Clients are advised that a conflict of interest exists when they pay us on a standalone basis for MPB services. The client is under no obligation to act upon the recommendation to use MPB. The IARs of Kovitz do not receive compensation for these recommendations. Additional information is provided in Item 5, 10 and 15.