The Audent Global Asset Management Wrap Program (the “Program”) is an investment advisory program sponsored by Audent. In addition to the Program, the Firm offers a variety of advisory services, which include financial planning, consulting, and investment management services under different arrangements than those described herein. Prior to Audent rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Audent setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Audent filed for registration as an investment adviser in April 2020 and is owned by Paul Feinstein. As of December 31, 2023 Audent, had $577,827,813 of assets under management, $422,340,965 are managed on a discretionary basis, while $155,486,848 are managed on a non-discretionary basis. While this brochure generally describes the business of Audent, 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 Audent’s behalf and is subject to the Firm’s supervision or control. Description of the Program The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement under which clients receive investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions for a specified fee or fees not based upon transactions in their accounts. Clients must also open a new securities brokerage account and complete a new account agreement with Pershing Advisor Solutions (“Pershing”), or another broker-dealer that Audent approves under the Program (collectively “Financial Institutions”). At the onset of the Program, the Firm gets to know the individual investment objectives, liquidity and cash flow needs, time horizon and risk tolerance of the client, as well as any other factors pertinent to their specific financial situations. After an analysis of the relevant information, Audent assists its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are generally managed on a discretionary basis by either Audent’s investment adviser representatives or an independent investment manager (collectively “Independent Managers”), as selected by Audent. Audent and/or the Independent Managers generally allocate clients’ assets among the various investment products available under the Program, as described further below. Investment Management Services Audent manages client investment portfolios on a discretionary basis. Audent primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, options, alternative investments (which can include privately placed securities) and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Audent 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, Audent 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. Audent 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. Audent 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 Audent if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Audent 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, Audent selects 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. Audent recommends to sophisticated and qualified investors private investment opportunities in single purpose vehicles and other private funds where we have a carried interest, either directly or indirectly through affiliated companies that we own. We often consult with the managing member and have a right to receive a portion of the profits related to those investments. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. We encourage you to ask us about these interests and to carefully review the related offering documents. Audent evaluates a variety of information about Independent Managers, which includes 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. Audent also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Audent continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Audent seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Fees for Participation in the Program The Program is offered on a fee basis, which includes fixed fees, as well as fees based upon assets under management (sometimes referred to as the “Program Fee”). Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offers securities brokerage services and/or insurance products under a separate commission-based arrangement. Investment Management Fees Audent offers investment management services for an annual fee based on the amount

of assets under the Firm’s management. This management fee varies depending upon the strategy being utilized, as follows:
• Carret Muni/Carret MO – 0.80%
• Carret Opportunity/ Carret Opp – 0.80%
• Carret Enhanced Cash/EC – 0.50%
• Bond Enhancement/BE – 0.80%
• Concentrated Equity/ CE – 1.4%
• Fallen Angels/ FA - 1.4%
• Special Purchase Account/ SPA – 1.0%
• Global Alpha Balanced Strategy/GABS – 1.0%
• Global Alpha Investment Strategy/ GAIS – 1.0% The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by Audent on the last day of the previous quarter as determined by a party independent from the Firm (including the client’s custodian or another third-party). If assets are deposited or withdrawn after the beginning of a billing period, the fee will be prorated and adjusted as part of the next quarter’s bill. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), Audent can negotiate a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Audent for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Private Fund Fees Audent offers private fund investment opportunities through pooled investment vehicles that execute on specific strategies. These private funds include single purpose vehicles designed to invest into a single investment opportunity or designed to execute on a specified securities investment strategy such as Concentrated Equity Strategy, Fallen Angels Strategy, Bond Enhancement Strategy, Global Alpha Income Strategy, Global Alpha Balanced Strategy or other strategies developed by Audent. We typically charge 20% carried interest or performance-based fee subject to a hurdle or clawback provision (as negotiated with each client). We also charge a management fee on select funds, which is individually negotiated with each private fund offered. Fee Comparison As referenced above, a portion of the fees paid to Audent are used to cover certain securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Because the Firm pays for the brokerage fees, the Firm has an incentive to engage in less transactions, or transactions that cost less to the Firm, including the use of mutual funds that do not have transaction charges, but have higher expenses to the client. The Firm reviews the frequency and type of investments made in client accounts to act in the client’s best interest. Fee Discretion Audent may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention, pro bono activities, or competitive purposes. Other Charges In addition to the advisory fees paid to Audent, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges include fees for trades executed away from Pershing (a conflict of interest exists where the Firm avoids expenses by trading through a different Financial Institution), mark-ups and mark- downs on fixed-income transactions (or it is overly burdensome to determine the amount of such mark-ups and mark-downs), fees charged by the Independent Managers, fees attributable to alternative assets, reporting charges, margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund Program Fees and other fund expenses), fees and commission for assets not held with Pershing (such as 401(k) or 529 plan assets), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees. Direct Fee Debit Clients provide Audent and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Audent. Alternatively, clients may elect to have Audent send a separate invoice for direct payment. Use of Margin Audent can be authorized by clients to use margin in the management of the client’s investment portfolio. In these cases the fee payable will be assessed net of margin such that the market value of the client’s account and corresponding fee payable by the client to Audent will not be increased. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time, subject to Audent’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to Audent, subject to the usual and customary securities settlement procedures. However, Audent designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Audent may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charge) and/or tax ramifications. Compensation for Recommending the Program Audent has internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation as a result of clients’ participation. Select Audent employees receive a percentage of total advisory fees received by Audent calculated as a percentage of assets under management. A person recommending the Program will not earn more compensation than he or she would otherwise receive if a client elected another investment management program.