Page 4 A. Description of Your Advisory Firm Alley Investment Management Company, LLC (“Alley Company” and/or the “firm”), is a registered investment advisory firm with the U.S. Securities and Exchange Commission. Alley Investment Management Company acquired the advisory business of Alley Company, LLC, which was established in 1998. Focus Financial Partners Alley Company is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Alley Company 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 Alley Company is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Alley Company. 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. Alley Company is managed by Steve Alley, Rik Duryea and Tom Van Vuren (“Alley Company Principals”), pursuant to a management agreement between AIMCO, LLC and Alley Company. The Alley Company Principals serve as leaders and officers of Alley Company and are responsible for the management, supervision and oversight of Alley Company. B. Description of Advisory Services Offered Alley Company provides a complete portfolio management service, commonly referred to as separate account management. This includes the purchase, sale, and continuous supervision of all assets under management. Generally, we invest in stocks, exchange-traded funds, and bonds, although stock options and convertible securities, among other investments, may be used in the customization of client portfolios or asset allocation programs. Alley Company will accept restrictions from clients on the use of certain securities in the portfolios. Our equity investment objective is to compound long-term rates of return in a tax-efficient manner in a separate account format. To achieve this goal, we make U.S. large-cap equities the centerpiece investment for our clients, because historically this asset class has produced attractive risk-adjusted returns. Page 5 Alley Company’s flagship equity strategies are the Alley Company

Core Portfolio, the Alley Company Dividend Portfolio, and the Alley Company Hybrid Portfolio. The Core Portfolio philosophy is to focus on growth companies with proven track records, astute management teams, and strong potential for sustainable growth. Our Dividend Portfolio philosophy is to invest in high-quality companies with strong dividend paying cultures. The Hybrid Portfolio is a blend of the Core and Dividend Portfolios. Alley Company builds asset-allocation programs for clients around the Alley Company Core, Dividend, and Hybrid Portfolios. We develop these programs using low-cost and tax-efficient exchange-traded funds as well as fixed-income products to meet client-specific needs. Alley Company also provides sub-advisory and model portfolio management services for other investment advisers using the aforementioned separate account disciplines. For its discretionary asset management services, Alley Company receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this brochure. In addition, pursuant to the terms of its investment advisory agreement with clients, Alley Company will remind clients of their obligation to inform Alley Company of any modifications or restrictions that should be imposed on the management of the client’s account. Alley Company will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Although Alley Company does not sponsor any wrap fee programs, the firm acts as a portfolio manager to the following wrap fee programs. Further information is available in the respective program’s wrap fee brochure.  Envestnet Asset Management’s Third-Party Models  ICR Partners LLC’s Model Hub  SMArtX Advisory Solutions  Fidelity Institutional Wealth Adviser LLC’s Fidelity Managed Account Xchange  LPL Financial’s Model Wealth Portfolio  LPL Financial’s Manager Select/Manager Access Select  Orion Portfolio Service LLC’s OPS Advisor Portal Page 6 E. Client Assets Under Management As of December 31, 2023, Alley Company is responsible for managing $4,233,586,533 in client assets. This value includes $727,106,652 in discretionary assets and $38,366,273 in non- discretionary assets under management; and $3,468,113,608 in Unified Managed Account (UMA) programs.
Item 5: Fees and Compensation