GeoWealth Management, LLC (“GeoWealth”) is a limited liability company organized in 2004 under the laws of the State of Delaware. The Firm is registered as an investment adviser with the SEC pursuant to the Investment Advisers Act of 1940 (“Advisers Act”). GeoWealth Holdings, LLC is the majority owner of GeoWealth through the subsidiaries GeoWealth Enterprises and GeoWealth, LLC. GeoWealth operates a Turnkey Asset Management Platform (“TAMP”) and provides digital advisory tools that investment advisors rely on for managing their client accounts. In a TAMP, clients typically work directly with their primary investment advisor to determine their investment needs given their unique circumstances. The primary investment advisor then relies on GeoWealth to purchase and sell securities, monitor investments, and perform various other functions. This enables investment advisors to focus their efforts on the individual needs of their clients. Typically, advisors will engage with GeoWealth in a sub-advisory or co-advisory capacity, however in certain circumstances clients will work directly with GeoWealth. GeoWealth is able to provide not only investment management services, but GeoWealth can also handle the operational aspects of account opening and administration. These services include but are not limited to account opening and closing, all interactions with the custodian, maintenance of account paperwork, processing of contributions and withdrawals, Roth conversions/IRA recharacterizations, account transfers, quarterly billing and performance reporting. In a direct advisory relationship, GeoWealth, as an SEC Registered Investment Advisor, offers consulting and investment supervisory services on managed investment accounts to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, business entities and corporations (the “client” or “client account”). For the small number of end-clients working directly with GeoWealth, the investment supervisory services include regular analysis and review of portfolios and advice concerning acquisition, retention, management, reinvestment and disposition of cash, securities and other assets

of the client’s portfolios. When investing model portfolios, GeoWealth generally has the discretion to determine when to purchase or sell securities and whether to accept the recommendation of the model provider. It is GeoWealth’s standard practice to invest all model portfolios in accordance with the recommendation of the model provider. For end-clients who work directly with GeoWealth, we will work with the client to understand the client’s financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. Once the client’s investment portfolio has been designed and investments have been allocated, we will provide ongoing portfolio review and management services. Clients can place reasonable restrictions on their investment portfolio such as transferring in securities to be held long-term and not sold. Such restrictions must be provided in writing to, and accepted by, GeoWealth. Our model marketplace offers risk-based, thematic and outcome-based third-party models from industry-leading providers. Through our TAMP and model universe, we ensure advisors have compliant and scalable solutions to respond to client needs. Additionally, we offer our own proprietary models and provide advisors the ability to offer their own proprietary models which GeoWealth services on their behalf. GeoWealth, in certain relationships with ERISA accounts, is section 3(38) “investment manager”. GeoWealth provides its 3(38) investment management services to ERISA Plans of advisors that it works with, that are on various record-keeping platforms. The 3(38) investments provided include, but are not limited to, certain of GeoWealth’s Model Portfolios, an investment line-up using securities representing a spectrum of asset classes and risk levels, and a qualified default investment alternative (or “QDIA") for the Plan, if required. We provide investment advice on either a discretionary or non-discretionary basis. As of March 22, 2024, GeoWealth managed approximately 5.8 billion of regulatory assets on a discretionary basis and approximately 6.5 billion of regulatory assets on a non-discretionary basis.