A. The Registrant (Brighton Jones, LLC) is a limited liability company formed on December 21, 1999, in the state of Washington. Brighton Jones became registered as an Investment Adviser in January 2000. Brighton Jones is principally owned by Charles Brighton and Jon Jones. Brighton Jones also conducts business as OpenPlan and Lenora Capital. All advisory services obtained through OpenPlan or Lenora Capital are provided by Brighton Jones. OpenPlan, founded in 2016 in the state of Washington, offers individual financial planning and retirement plan advisory services. Lenora Capital, founded in 2022 in the state of Washington, offers Brighton Jones clients private investment services. It is important to note that responses from Brighton Jones also pertain to OpenPlan and Lenora Capital unless specifically stated otherwise. B. BRIGHTON JONES PERSONAL CFO (PCFO) SERVICES For high-net-worth clients, Brighton Jones’ Personal Chief Financial Officer (PCFO) offering provides comprehensive and ongoing strategic wealth management services consisting of: financial planning and consulting; discretionary investment management; and continuous monitoring, each of which are described in more detail below. These services are provided on a fee-only basis, subject to the terms and conditions of an agreement between Brighton Jones and the client. Brighton Jones generally believes that these services should extend to a clients' entire balance sheet, ensuring that our advice considers their complete financial picture and aims to enhance overall wealth. However, clients have the option to request, in writing or through an addendum to their client service agreement, that certain assets be excluded (the “Excluded Assets”) from our advisory scope. In such cases, Brighton Jones will not incorporate these Excluded Assets into our financial planning and consulting or discretionary investment management services, and clients will bear sole responsibility for the performance of those assets. Excluded Assets are not subject to PCFO advisory fees. If Brighton Jones determines in its sole discretion that the client requires services that exceed the scope of the agreement, Brighton Jones will present the client with a separate agreement or addendum to memorialize the applicable terms and conditions of a proposed separate or expanded engagement. Annual PCFO fees include the services described below: Financial Planning and Consulting Services. Brighton Jones provides PCFO clients dedicated teams led by experienced Lead Advisors, serving select client groups across the United States. Our comprehensive approach involves thorough analysis of clients' total balance sheets within our PCFO framework. We provide tailored recommendations aligned with clients' investment objectives, values, risk tolerance, and financial and personal circumstances. Please see Item 8 below for discussion on certain limitations applicable to financial planning and consulting services. Discretionary Investment Management Services. Brighton Jones also assumes full discretionary authority over the investment and reinvestment of the client’s securities accounts, unless otherwise noted in an addendum to their PCFO agreement. Brighton Jones may buy, sell, trade and allocate in and among stocks, bonds, mutual funds, exchange traded funds, cash / cash equivalents, sub-advisory accounts, investment subdivisions within variable annuity products, accounts with independent investment managers and/or programs (with or without discretion, depending upon the independent investment manager or program) and other securities or contracts relating to the same, on margin (only if written authorization by the client has been granted) or otherwise, consistent with the client’s then- current circumstances and investment objectives. As indicated in Item 16 below, clients receiving discretionary management may, at any time, impose reasonable restrictions on Brighton Jones’ discretionary authority. Continuous Monitoring and Reporting Services. Brighton Jones may also provide comprehensive reporting services through its designated online client portal which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by Brighton Jones (the “Excluded Assets”). Should the client receive such reporting services, the client acknowledges and understands that with respect to the Excluded Assets, Brighton Jones’ service is limited to reporting services only and does not include investment management, review, or monitoring services, nor investment recommendations or advice. In the event the client desires that Brighton Jones provide financial planning and consulting or discretionary investment management services with respect to the Excluded Assets, the client may engage Brighton Jones to do so under the terms and conditions of their service agreement, or for a separate and/or additional fee pursuant to the terms and conditions of a separate agreement. OPENPLAN INDIVIDUAL FINANCIAL PLANNING (IFP) SERVICES Brighton Jones, through OpenPlan, provides initial and ongoing strategic wealth management services consisting of: financial planning and consulting; optional discretionary investment management; and continuous monitoring as part of its IFP services for clients starting their wealth management journey. These services are provided on a fee-only basis, subject to the terms and conditions of an agreement between OpenPlan and the client. Unlike Brighton Jones’ PCFO service, OpenPlan clients are primarily responsible for the execution of the investment strategy provided by OpenPlan advisors. Financial Planning and Consulting Services. OpenPlan provides financial planning services (including investment and non-investment related matters, such estate planning, insurance planning, taxes, real estate, cash flow planning, etc.). Before engaging us to provide planning services, clients are generally required to enter into an agreement with us setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to OpenPlan commencing services. Please see Item 8 below for discussion on certain limitations applicable to financial planning and consulting services. Discretionary Investment Management Services. Clients have the option to delegate discretionary investment management and execution of the investment plan to OpenPlan for a portion or all their assets for which OpenPlan provides financial planning and consulting services. These services are subject to the terms and conditions of a separate agreement, and a separate fee for the assets under management. Clients acknowledge that any assets for which OpenPlan is not specifically delegated as having discretionary investment management over, are considered Excluded Assets, and not subject to additional fees. As indicated in Item 16 below, clients receiving discretionary management may, at any time, impose reasonable restrictions on Brighton Jones’ discretionary authority. Annual Monitoring and Reporting Services. All IFP clients are provided access to eMoney, a third party financial planning software, so that they may continuously monitor portfolio performance. On an annual basis, or as specifically requested by the client, OpenPlan may review client asset allocation as compared to client investment objectives. For assets which the client has delegated discretionary authority, OpenPlan periodically executes or recommends execution of account transactions based upon such reviews. The client acknowledges and understands that with respect to the Excluded Assets, our service is limited to reporting services only and does not include investment management, review, or monitoring services, nor investment recommendations or advice. As such, the client, and not OpenPlan, shall be exclusively responsible for the investment performance of the Excluded Assets. In the event the client desires that we provide discretionary investment management services with respect to the Excluded Assets, the client may engage us to do so for a separate and/or additional fee pursuant to the terms and conditions of a separate agreement between us and the client. OPENPLAN RETIREMENT PLAN ADVISORY (RPA) SERVICES Brighton Jones,

through OpenPlan, provides retirement plan consulting/management services, pursuant to which it assists sponsors of pooled employer and self-directed retirement plans organized under the Employee Retirement Security Act of 1974 (“ERISA”). The terms and conditions of the engagement shall be set forth in an agreement between OpenPlan and the plan sponsor. Retirement Plan Consulting/Management Services. If the plan sponsor engages the OpenPlan in an ERISA Section 3(21) capacity, OpenPlan will, on a non-discretionary basis, assist with the selection and/or monitoring of investment options (generally open- end mutual funds and exchange traded funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. If the plan sponsor chooses to engage OpenPlan in an ERISA Section 3(38) capacity, OpenPlan may provide the same services as described above, but may also: create specific asset allocation models that OpenPlan manages on a discretionary basis, which plan participants may choose in managing their individual retirement account; and/or modify the investment options made available to plan participants on a discretionary basis. Financial Wellness Consulting. OpenPlan may also provide Financial Wellness seminars to a retirement plan’s participating employees on issues such as educational funding, life insurance coverage, estate planning, retirement planning, and recent developments in the financial services industry or regulations. The number and frequency of the seminars is subject to negotiations between OpenPlan and the employer. Generally, before engaging OpenPlan to provide Financial Wellness Consulting services, clients are required to enter into an RPA agreement with us setting forth the terms and conditions of the engagement. In some cases, we may offer Financial Wellness Consulting services to non-RPA clients, subject to the terms and conditions of a standalone agreement. OTHER FINANCIAL SERVICES PROVIDED BY BRIGHTON JONES AND AFFILIATES Brighton Jones may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Brighton Jones does not serve as an attorney or insurance agency, and no portion of its services should be construed as legal or insurance brokerage services. Accordingly, Brighton Jones does not prepare estate planning documents or sell insurance products. To the extent requested by a client, Brighton Jones may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance agents, etc.) including certain of Brighton Jones representatives in their separate and individual capacities as Certified Public Accountants or licensed attorneys as described in Item 10.C below. Clients are under no obligation to engage the services of any recommended professionals. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from Brighton Jones. If the client engages any recommended professional, and a dispute arises thereafter relative to the engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e. attorney, accountant, insurance agent, etc.), and not Brighton Jones, shall be responsible for the quality and competency of the services provided. Tax Preparation Services through Brighton Jones. Brighton Jones offers comprehensive tax preparation and filing services. Brighton Jones charges clients a separate fee (fixed or hourly) for tax preparation services, depending upon the scope and complexity of the services required. To the extent that a client engages Brighton Jones to provide such services, the client shall execute a separate agreement or an addendum to their PCFO services agreement which will detail the services to be provided and the separate fee paid by the client for those services. Corporate Transparency Act (CTA) Filing Services through Brighton Jones. Upon the client’s written request, Brighton Jones may arrange to support Client’s compliance with the Corporate Transparency Act (“CTA”). Such services may be provided by Brighton Jones at an additional cost and under the terms and conditions of a separate agreement or an addendum to their PCFO services agreement. Private Investments through Lenora Capital. Lenora Capital, LLC is a wholly owned subsidiary of Brighton Jones, LLC. Lenora Capital is the LLC manager of various private funds for which Brighton Jones, LLC serves as investment manager. The funds act as vehicles for Brighton Jones to consolidate client capital for the purposes of making private investments. For qualified clients or qualified purchasers, Brighton Jones may make recommendations to invest in private funds offered through Lenora Capital, LLC. The funds that clients may be referred to invest in are Lenora Capital MultiStrategy Fund I, LLC, and Lenora Capital MultiStrategy Fund I (QP), LLC. Tax Advantage Investments through Brighton Jones Real Estate Advisors. Brighton Jones offers tax advantage securitized real estate investment opportunities through Brighton Jones Real Estate Advisors, LLC (BJREA). In the event that clients choose to engage BJREA to provide real estate investment services, those services shall be provided through BJREA pursuant to a separate agreement and subject to a one-time only administrative flat fee, organized in a tier structure, based on the amount of principle invested. Investment advice related to BJREA services is provided by Brighton Jones and the client’s service team. BPC REIT and Blueprint Capital Services. Brighton Jones is the majority owner of Blueprint Capital Services, LLC (“Blueprint”), the manager of the BPC REIT. Blueprint provides management services on a fee basis to the BPC REIT. Estate Planning Services through 2030 Law. Certain of Brighton Jones’ supervised persons are also, in their separate and individual capacities, licensed attorneys. These individuals offer their legal services, as part of 2030 Law, separate and apart from Brighton Jones. Clients with a net worth over $15 million may engage these individuals to provide legal services subject to the terms and conditions of a separate agreement and service fee. Other Estate Planning Services through Brighton Jones. Brighton Jones utilizes Wealth, Inc. as part of our commitment to providing comprehensive estate planning services, enabling clients to effectively manage their legacy and ensure their wishes are carried out according to their preferences. Resources offered by Wealth, Inc. include, without limitation, creation of estate planning documents from templates and forms for revocable trusts, pour-over wills, last will and testaments, financial power of attorneys, advance health care directives, guardianship nominations, deed transfers through the attorney consultation feature, and gift and estate tax projections with a visual report. Clients may engage these services according to the terms and conditions specified in a separate addendum to their client service agreement. Services are subject to a one-time only fee which is variable depending on the complexity of the client’s needs. In these engagements, Brighton Jones may be granted view-only access to a client’s estate planning progress, but the underlying legal and estate planning services will be provided by Wealth.com or one or more of the platform’s engaged professionals. C. Brighton Jones shall provide investment advisory or management services specific to the needs of each client. Before providing investment advisory or management services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Brighton Jones shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Brighton Jones’ services. D. Brighton Jones does not participate in or sponsor a wrap fee program. E. As of As of December 31, 2023, Brighton Jones had $12,393,371,217 in assets under management on a discretionary basis and $94,977,287 in assets under management on a non-discretionary basis.