Firm Overview Rockefeller Financial LLC (“Rockefeller Financial” or the “Firm”), a Delaware limited liability company is an investment adviser registered with the U.S. Securities and Exchange Commission (the “SEC”) and a registered broker-dealer and a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”). The Firm also does business under the name Rockefeller Capital Management and Rockefeller Global Family Office. Rockefeller Financial provides comprehensive wealth management services to high net-worth and ultra-high net worth clients. In its capacity as a broker-dealer, the Firm will also affect securities transactions for clients, sell variable insurance products and provide investment banking services specifically providing strategic advice with respect to mergers, acquisitions, and dispositions of businesses and on other types of strategic transactions. Rockefeller Financial is a wholly-owned subsidiary of Rockefeller Capital Management L.P. (“RCM”). RCM was established on March 1, 2018, when Gregory J. Fleming, together with investment funds affiliated with Viking Global Investors LP (“Viking”), acquired the investment advisory and trust company businesses established by the Rockefeller family. Today, RCM is majority owned by the Viking funds, with minority stakes held by a U.S. affiliate of IGM Financial Inc. (“IGM”), a trust representing the Rockefeller family, and current and former members of RCM’s management and individual members of the Rockefeller family. Viking and IGM are not involved in the day-to-day management of RCM or the Firm. No employee, officer, director, or other representative of Viking or IGM, or any of their respective controlled affiliates, is a member of any committee of RCM or the Firm that determines which products or services are offered or sold to Firm clients. RCM’s operating subsidiaries include: Rockefeller Financial; Rockefeller & Co. LLC (“Rockefeller & Co.”), an investment adviser registered with the SEC providing global family office and asset management services through its Rockefeller Asset Management (“RAM“) division; Rockefeller Asset Management International Ltd. (“RAM International”), a UK limited company performing non-US distribution and investor servicing activities for RAM to non-U.S. intermediaries and professional clients; Rockefeller Trust Company, N.A., a national trust bank regulated by the Comptroller of the Currency (“RTC NA”) and The Rockefeller Trust Company (Delaware), a limited purpose trust company regulated by the Office of the State Bank Commissioner of the State of Delaware (“RTC DEL”), both of which provide fiduciary services acting either as a trustee, co-trustee, executor, co-executor, or as a fiduciary or agent for other fiduciary relationships; Rockefeller Strategic Services LLC (“Rockefeller Strategic Services”), which provides strategic advisory services with respect to certain types of business transactions not requiring registration in the U.S. as a broker dealer; and Rockefeller Capital Management Insurance Services, LLC (“Rockefeller Capital Management Insurance Services”), an insurance company licensed in all 50 U.S. states that provides access to a broad range of personal insurance expertise and services through numerous national providers to enable effective estate planning, asset protection or other key wealth management planning strategies and priorities. Unless otherwise specified, references herein to “clients” or “you” refer to advisory clients of Rockefeller Financial and the descriptions of advisory services and other securities business practices refer to those of Rockefeller Financial, and not to the advisory services and business practices of its affiliates, including Rockefeller & Co., RTC NA, RTC DEL, Rockefeller Strategic Services and Rockefeller Capital Management Insurance Services. Rockefeller Financial Investment Advisory Services Rockefeller Financial provides discretionary and non-discretionary investment advisory services (“Investment Advisory services”) across a broad range of asset classes and investments to ultra-high net worth and high net worth individuals, their families, family offices and entities such as trusts, estates, endowments and foundations, as well as pension, profit sharing and other retirement plans, charitable organizations, corporations and other businesses, and state or municipal government entities. Clients receive personalized investment advice and guidance from their Private Advisor (“PA”). The Firm’s investment process generally begins by PAs helping clients define their goals, objectives and risk tolerances. Once these investment parameters are agreed upon, your PA will develop or refine, in consultation with you, an asset allocation framework, provide strategic and tactical asset allocation advice based upon this framework, subject to any reasonable guidelines and restrictions agreed upon in writing with you, and provide you with recommendations on a variety of products including equity securities and fixed income products, investment managers, mutual funds, exchange traded funds (“ETFs”), alternative investments, structured products and variable annuities. You will receive account statements to help inform and ensure that the products and services are in line with your investment parameters. You are encouraged to, and are responsible for, promptly notifying your PA in writing of any material changes in your investment objectives or financial situation. You may obtain information about your PA, their licenses, educational background, employment history, and if they have had any problems with regulators or received serious complaints from investors through FINRA BrokerCheck, available at https://brokercheck.finra.org or from the Securities and Exchange Commission at www.adviserinfo.sec.gov. In addition, some of our PAs may hold certain professional educational credentials, such as the Certified Financial Planner (“CFP”) or the Chartered Financial Analysist (“CFA”) designation. Holding a professional designation typically indicates that a PA has completed certain courses or continuing education. However, a PA’s professional designation does not change the obligations of the Firm in providing investment advisory or brokerage services to you. It is important to understand that investment advisory services and brokerage services are separate and distinct from each other, and each is governed by different laws and separate arrangements that we may have with you. The specific services or investment strategies that we provide, our relationship with you and our legal duties to you in each arrangement are described in detail in our applicable contracts with you. When we act as your investment adviser, we receive either a flat annual dollar fee or fees calculated on a percentage of assets in your account (both discussed in more detail in Item 5 below). Accordingly, in some cases, we and our PAs earn more when you invest more in your advisory account, and we earn the same advisory fee rate regardless of how frequently you trade. We also receive payments from third parties, including from the sponsors of the investment products in which you invest. In circumstances where we receive a fee based on the percentage of assets in your account, we have an incentive to recommend that you increase the assets in your advisory accounts to increase our fees, to invest in investment products that result in greater compensation to us (including products and services provided by us and our affiliates or those for which we receive a portion of product-level fees that you pay), to maintain cash balances in a sweep investment, and to recommend sweep accounts that result in higher fees for us (Please see Item 5 – Fees and Compensation below for additional information and Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading for additional information regarding associated conflicts of interest). Rockefeller Financial also separately offers brokerage account services (“Brokerage Account services”) that give you the option of investing through a non-discretionary, commission or transaction- based account. When we act as broker-dealer, we are compensated by the commissions and fees you pay us as well as through the revenue we receive from third parties that include the sponsors of investment products that we recommend to you. This compensation structure leads to certain conflicts. Brokerage Account services may be more appropriate than Investment Advisory services if you do not want ongoing investment advice or management of your account, but instead desire only periodic or on-demand recommendations and/or wish to pay transaction-based compensation for those trades that you authorize us to make on your behalf. By utilizing our Brokerage Account services, you will be electing to have a relationship with us under which, on a transaction-by-transaction basis, we assist you and give you recommendations which are suitable for your account and in your best interest based on information you provide to us. This is in contrast to a relationship in which we manage your account assets on a discretionary basis and monitor your account in our capacity as an investment adviser. For more information about Rockefeller Financial’s brokerage services, benefits, risks, conflicts and costs, please see the Rockefeller Financial LLC Client Relationship Brochure which your PA can furnish to you. Types of Services We generally offer several types of services including, Non- discretionary Consulting Services, Investment Advisory Services, Retirement Plan Investment and Consulting Services, and Financial Planning Reports and Analyses, each as described in further detail below, and may in the future expand these services to include separately managed account (“SMA”) strategies offered through dual contract arrangements through a proprietary or third-party asset management firm. Rockefeller Financial is the sponsor of the Rockefeller Private Wealth Advisory Platform (the “Platform”), a wrap fee program through which it provides discretionary and non-discretionary investment advisory services to clients across a broad range of asset classes and investments. In a wrap fee program, the client pays Rockefeller Financial a single, bundled, or “wrap” fee for investment advice, brokerage services, administrative expenses, and certain other fees and expenses. The Wrap Fee Program is detailed in a separate wrap fee brochure (the “Wrap Brochure”). Strategies offered to advisory clients may not be suitable for all of your investments and Rockefeller Financial does not represent that any particular strategy is based on or meant to replace a comprehensive evaluation of any client’s entire financial life considering all of such client’s circumstances. Instead, Rockefeller Financial’s advice and recommendations are specific to assets we manage in your account pursuant to the client agreement applicable to the Investment Advisory services we provide (“Client Agreement”). We do not consider assets in accounts we do not manage pursuant to the Client Agreement, if any, and those held outside of your account, including assets that may be held in other accounts at Rockefeller Financial or its affiliates. For each of the Investment Advisory service offerings described in this Brochure, Rockefeller Financial does not provide any custodial, trade execution, or other account services for investments or other assets, investments or other assets are maintained at an unaffiliated broker-dealer, retirement administrator or other qualified custodian (“Third-Party Custodian”). Each client is responsible for separately making arrangements with any Third-Party Custodian for such services and to pay any applicable commissions, charges, trails, and other account, brokerage or custodial fees directly to the Third-Party Custodian. Investment Consulting Services and Investment Advisory Services Rockefeller Financial offers non-discretionary consulting services as well and discretionary and non-discretionary Investment Advisory Services to institutions, endowments, pension, individuals, and other clients. Depending on the type of client, we may provide one or more investment advisory services, including the following: (1) Non-Discretionary Investment Consulting Services:
• Assist client in the preparation of investment objectives and policies
• Assist client in the creation of an investment policy statement ("IPS")
• Provide client advice regarding investment of account and/or trust fund
• Provide client assistance with fund searches
• Provide advice regarding third-party investment advisers and/or managers
• Provide client with periodic performance reporting Rockefeller Financial does not have discretionary authority over clients’ assets in these Third-Party Custodian accounts. Clients have sole discretion to accept or reject any investment advice or strategy or any specific recommendation to purchase or sell an individual investment. Clients are also responsible for implementing or arranging with the Third-Party Custodian for the implementation of, any advice provided by Rockefeller Financial. You may make investment-related decisions contrary to the advice provided or make your own decisions without the benefit of our advice. However, if you decide to repeatedly disregard our investment advice, your account may be better suited to a brokerage relationship in which you pay brokerage commissions or other transaction-based compensation instead of ongoing investment advisory fees. (2) Investment Advisory Services In connection with Investment Advisory services, the Firm, through its PAs, provides clients with one or more discretionary or non- discretionary investment recommendations, advice, assistance and related services as clients and their PAs may agree, including related to: asset allocation; existing and potential investment strategies; existing investment holdings; the purchase or sale of securities, funds and other investment products and services; and/or performance, analytical or planning reports. Rockefeller Retirement Plan Investment and Consulting Services Rockefeller Financial offers services to plan sponsors and other named fiduciaries (“Plan Sponsors”) of trustee directed and participant directed retirement plans (each, a “Plan”), some of which are subject to the Employee Retirement Income Security Act (“ERISA”) as well as non-discretionary investment advisory services to sponsor clients, which services encompass (1) Non-Discretionary Investment Advisory Services, (2) Discretionary Investment Advisory Services and/or (3) Retirement Plan Consulting Services to employer-sponsored retirement plans and their participants. Depending on the type of the Plan and the specific arrangement with the Plan Sponsor, we may provide one or more of the below- described services. Prior to being engaged by the Plan Sponsor, we will provide a copy of the Retirement Plan Investment Consulting Services Client Agreement ("Retirement Plan Agreement") that contains the information required under Sec. 408(b)(2) of ERISA as applicable. Rockefeller Financial does not have discretion nor any authority over the Plan’s documents. Depending on the services selected, Rockefeller Financial may or may not have discretion with respect to the Plan’s investment program. Whether Rockefeller Financial has discretion and, if so, the extent of such discretion, is explicitly stated in the relevant Agreement that you will execute with Rockefeller Financial. We will collect certain information from you to assist in recommending and providing the services selected at the initiation of services and periodically thereafter. You should provide prompt written notice to Rockefeller Financial of any change in Plan Sponsor information and any change in your Plan’s investment objectives, guidelines, or similar information, which could materially change the information previously provided by you and which you expect should be used by us to provide any advice. (1) Non-Discretionary Investment Advisory Services Rockefeller Financial provides non-discretionary investment advisory services to Plan Sponsor clients with respect to investments or other assets held at one or more Third-Party Custodians.

These services are designed to allow the plan fiduciary to retain full discretionary authority or control over assets of the plan fiduciary. We will solely be making recommendations to the Plan Sponsor. We will perform these non-discretionary investment advisory services through our PAs and charge fees as described in this Form ADV and the Retirement Plan Agreement. If the Plan is covered by ERISA, we will perform these investment advisory services to the Plan as a “fiduciary” defined under ERISA Section 3(21). The Plan Sponsor may engage us to perform one or more of the following non-discretionary investment advisory services:
• Advice regarding establishing an IPS
• Advice regarding selection of designated investment alternatives (“DIAs”)
• Advice regarding selection of third-party investment advisers and/or managers
• Advice regarding selection of qualified default investment alternative (“QDIA(s)”)
• Advice regarding investment of trust funds.
(2) Discretionary Investment Advisory Services Rockefeller Financial provides discretionary investment advisory services to plan sponsor clients with respect to investments or other assets held at one or more third-party custodians. These services are designed to allow the plan fiduciary to delegate responsibility to Rockefeller Financial for maintaining the plan’s designated investment alternatives and qualified default investment alternatives in compliance with the requirements of the Employee Retirement Income Security Act of 1974 ("ERISA"). We will perform these investment management services, and charge fees as described in this Form ADV and the Agreement executed with plan sponsor clients. We will perform these services as an “investment manager” as defined under ERISA section 3(38) and as a “fiduciary” to the plan as defined under ERISA section 3(21), where applicable. As part of the discretionary investment advisory services, we may provide, based on the plan fiduciary’s instructions, the following services:
• Creation and Management of Plan-Level Investment Policy Statement (“IPS”)
• Selection, Monitoring and Replacement of designated investment alternatives ("DIAs")
• Creation and Maintenance of Model Asset Allocation Portfolios ("models")
• Selection and Replacement of third-party advisors and/or managers
• Selection, Monitoring & Replacement of qualified default investment alternatives ("QDIA(s)"). (3) Retirement Plan Investment Consulting Services Rockefeller Financial Retirement Plan Consulting Services are designed to allow our PAs to assist the Plan Sponsor in meeting its fiduciary duties to administer the Plan in the best interests of Plan participants and their beneficiaries. Retirement Plan Consulting Services are performed so that they would not be considered “investment advice” under ERISA. The Plan Sponsor may elect for our PA’s to assist with a number of Retirement Plan Consulting Services related to administrative support, service provider support, investment monitoring support and participant services. Depending on the specific client needs, services can range from assisting plan fiduciaries with committee policies/procedures, fiduciary education and assistance with covered services providers. Additionally, services may include assisting the plan committee with monitoring investment performance and assistance with participant enrollment meetings and participant investment education. (4) Rockefeller Personalized Portfolios In plans for which we provide Retirement Plan Investment and Consulting Services we may also provide a web-based, managed account services to plan participants (“Rockefeller Personalized Portfolios”). This program is not available to all plans and depends upon the Plan Sponsor’s selection of recordkeeper or custodian and authorization from the plan sponsor. Rockefeller Personalized Portfolios is a managed account service for participants who wish to have an investment manager select their investments from among the Plan’s available investment options and manage their accounts for them. Participants receive a personalized investment portfolio that reflects the Rockefeller Personalized Portfolios investment options and the Participant’s retirement timeframe, life stages, risk tolerance and overall financial picture, including assets held outside the Plan (if the participant elects to provide this information), which may be taken into consideration when determining the allocation of assets in the participant’s account Rockefeller Personalized Portfolios does not provide advice for, recommend allocations of, or manage a participant’s outside or non- Plan assets. Moreover, Rockefeller Personalized Portfolios will not include management services for individual stocks, self-directed brokerage accounts, guaranteed certificate funds, employer-directed monies or in-plan annuities. Under Rockefeller Personalized Portfolios, the Plan Sponsor will enter into a written agreement with Rockefeller Financial and any plan participant enrolling in the service will have to opt-in to the program. Rockefeller Financial will have discretionary authority over allocating the participant’s account, without participant approval of each transaction. If the plan is subject to ERISA, we agree to be held to a “fiduciary” standard of care with respect to our management of the participant’s account. Rockefeller Personalized Portfolios assets will be monitored, rebalanced and reallocated periodically (typically quarterly) by Rockefeller to respond to deviations resulting from market performance. Participants will receive an account update statement periodically and can review and update personal information at any time by calling the Plan’s toll-free customer service number or by visiting the Plan’s web site. Enrolled participants must allocate all of their plan account balance to the Rockefeller Personalized Portfolio assets. Participants are under no obligation to use these services and are freely able to use similar services offered by other firms. Participants may cancel their participation in Rockefeller Personalized Portfolios at any time. Potential Additional Retirement Services Provided Outside of the Retirement Plan Agreement In providing services for retirement plans, including Plans, (“Retirement Plan Services”), Rockefeller Financial and our PAs may establish a separate client relationship with one or more Plan participants or beneficiaries. Such separate client relationships develop in various ways, including, without limitation:
• as a result of a decision by the Plan participant or beneficiary to purchase services from us not involving the use of Plan assets;
• as part of an individual or family financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relating to assets held outside of the Plan; or
• through a rollover of an Individual Retirement Account ("IRA Rollover"). If we are providing services to Plan participants or beneficiaries separate from our providing services for their Plans as part of our Retirement Plan Services, we will do so through a separate agreement with such Plan participants or beneficiaries. If a Plan participant or beneficiary desires to affect an IRA Rollover from a Plan to an account advised or managed by Rockefeller Financial, the PA will have a conflict of interest if his/her fees in connection with providing services to such participant or beneficiary are reasonably expected to be higher than those we would otherwise receive in connection with the Retirement Plan Services. If a Plan participant or beneficiary desires to affect an IRA Rollover from the Plan to an account advised or managed by Rockefeller Financial, we and your PA will earn compensation on those assets, for example, through Client Fees based on the assets in the participant or beneficiary’s account, and third-party payments disclosed in this Brochure. This creates an incentive for us to recommend and encourage the rollover of assets from the Plan to us. We mitigate these conflicts by disclosing them and by establishing policies and procedures, and risk-based supervision to review these rollover recommendations. The fees and expenses applicable to an IRA likely will be higher than those paid through the Plan, and there can be other fees, including IRA termination fees. If a PA recommends moving retirement assets to Rockefeller Financial, he or she is required to consider, based on the information you provide, whether you will be giving up certain investment-related benefits at the Plan or other financial institution, such as the effects of breakpoints, rights of accumulation, and index annuity caps, and has determined that the recommendation is in your best interest, including, as applicable, for these reasons:
• Greater services and/or other benefits (including holistic advice and planning) can be achieved with the Rockefeller IRA;
• Consolidation of assets and availability of consolidated statements and performance reports would be beneficial to you; and
• The costs associated with Rockefeller IRA are justified by these services and benefits. The PA will disclose relevant information about the applicable fees charged by Rockefeller Financial in connection with any such IRA Rollover prior to opening an IRA account. Any decision to effect a rollover or about what to do with the rollover assets remain that of the Plan participant or beneficiary alone. In providing these optional services, we may offer participants and beneficiaries information on other financial and retirement products or services offered by Rockefeller Financial, our affiliates and our PAs. Financial Planning Reports and Analyses Upon request, Rockefeller Financial will provide clients with reports and/or analyses on one or more financial planning topics, including cash flows, income needs, asset allocation, retirement and life insurance assessments, charitable giving, estate and wealth transfer, and business succession. Those clients seeking financial planning services will generally enter into a separate Financial Planning Services Client Agreement with Rockefeller Financial, which sets forth the specific financial planning services to be provided, the reports and analyses that Rockefeller Financial will provide, and the fees that the client agrees to pay. The reports and analyses are for informational purposes only and are based upon information provided by the clients, and is intended to provide broad, general guidelines on the advantages of certain financial planning concepts. The reports and analyses do not constitute a recommendation of any particular technique or strategy, or of any particular investment type or investment opportunity. The reports and analyses do not provide on-going investment advice and are current only as of the date of each respective report. It is each client’s responsibility to determine what action, if any, you wish to take based on the information provided, and you are not required to transact business with us if you choose to implement any aspects of the report. Rockefeller Financial will only act upon your specific instructions. We do not undertake to monitor your account assets in connection with providing these financial planning reports and analyses. Certain reports and analyses may provide projections based on various assumptions, are hypothetical in nature, are subject to important limitations, and are not a guarantee of investment returns. Rockefeller Financial may also provide one or more financial planning reports or analyses without a separate charge as part of the overall services provided to its clients. SMA Dual Contract Arrangements Rockefeller Financial may also, through dual contract arrangements, provide Clients with access to certain affiliated and/or third-party investment managers’ separately managed account strategies that are not available on the Firm’s Private Wealth Advisory Platform. Clients investing through a dual contract arrangement are expected to receive personalized investment advice and guidance through their PA, including ongoing asset allocation, investment manager recommendations and monitoring, rebalancing, account review and other advice. Clients will separately enter into discretionary advisory agreements with one or more investment managers that will manage the Clients’ assets on a discretionary basis in accordance with the investment strategy or strategies selected. Investment managers available through dual contract arrangements will be limited. Dual contract arrangements, to the extent offered, will be offered as either wrap fee or investment advisory fees plus commission arrangements. In the latter arrangement, clients are charged asset- based fees for the investment advisory services provided by Rockefeller Financial and the investment managers. Investment advisory fees will be calculated based on an annual percentage of the value of a client’s assets under management. Brokerage commissions and/or transaction fees are charged to and deducted directly from your account for effecting securities transactions and other brokerage and custody services. Sub-Advisory Arrangements The Firm also acts as sub-adviser to investment advisory firms that manage investments on behalf of variable life insurance policies, variable annuity policies and other variable contracts. The Firm, through its PAs, manages accounts on a discretionary basis based on the investment objectives, policies and other parameters as directed by the client and/or the client’s investment adviser. The Firm is compensated by the client’s investment adviser pursuant to an arrangement as agreed to by the Firm and the investment adviser. Available Service Features Customized Advisory Services and Client Restrictions The Firm will tailor its advisory services to the individual needs of clients in accordance with the investment mandate for the account. Clients should communicate to their respective PA in writing any changes in the client’s financial situation or investment objectives, and whether the client wishes to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Clients may impose reasonable investment restrictions on the management of their accounts which, if accepted by Rockefeller Financial in writing, will apply until changed or withdrawn by the client or until Rockefeller Financial determines that the restriction is no longer reasonable or prevents the efficient management of the account. Client-imposed investment restrictions will not apply to investments held through investments in mutual funds and other comingled investment vehicles, which have their own stated investment objectives and policies. We reserve the right to deem any proposed investment restriction to be unreasonable and to not accept the proposed investment restriction. If one or more investment restrictions is determined to be unreasonable, we may not be able to accept management of the account. If you elect to restrict investments, you accept any effect such restrictions may have on the investment performance and diversification of your portfolio. The performance of accounts with investment restrictions or screens will differ from, and may be lower than, the performance of accounts without such restrictions or screens. Management by Certain Advisory Affiliates Certain advisory accounts will receive advice from Rockefeller Asset Management (“RAM”), a division of Rockefeller & Co., which is actively involved in managing certain equity and fixed income investments on the Firm’s Private Wealth Advisory Platform. These or other advisory affiliates may provide additional services in the future. Further, clients are from time to time offered access to mutual funds, private funds, and other securities offered and/or managed by RAM, Viking, or other advisory affiliates of Rockefeller Financial. Assets Under Management As of December 31, 2023, Rockefeller Financial’s Regulatory Assets Under Management were $51,821,018,176 which includes assets for services described in this Brochure as well as the Wrap Fee Brochure. Of those Regulatory Assets Under Management, $48,914,897,306 was managed on a discretionary basis, and $2,906,120,870 was managed on non-discretionary basis.