Empirical Financial Services, LLC d/b/a Empirical Wealth Management (“Empirical”, “EWM”, “us”, we”) is registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Kenneth Smith started Empirical Financial Services, LLC (“EFS”) in December 2009. The company is a spin-off of Empirical Wealth Management, an Oregon limited liability company that Mr. Smith was a founding member of in 2006. On December 31, 2012, EFS purchased Empirical Wealth Management, LLC from its remaining original members, re-merging both companies as a Washington limited liability company under the name of Empirical Financial Services, LLC d/b/a Empirical Wealth Management. Empirical’s CEO and founder, Kenneth Smith, is Empirical’s majority owner. The following Empirical employees own a minority interest: Ethan Broga, Lorne Enquist, Michael Kelly, Shan Zubair, James Jones II, Simon Liu, Erik Lehr, and Joseph Mercado. As of December 31, 2023, Empirical manages $5,519,025,932 on a discretionary basis and $6,158,819 on a non- discretionary basis. Investment Advisory Services Empirical provides fee-based, discretionary and non-discretionary investment management services. Empirical also sponsors and provides portfolio management services for a wrap-fee program that allows eligible client accounts to be charged a single fee that is comprehensive. We do not manage wrap-fee accounts differently than other accounts. As a portfolio manager to a wrap-fee program, we receive a portion of the wrap fee for our services. Advisory services encompasses a wide range of investment goals and risk tolerances, from conservative to aggressive, to meet the client’s specific investment needs. We begin by offering a comprehensive financial plan that helps create a picture of a client’s financial condition and personal financial goals. The plan also acts as a tool that helps clarify a client’s investment and life objectives. Clients can impose reasonable restrictions, in writing, on investing in certain securities or types of securities. Account restrictions are generally, but not always, for tax purposes in situations where a client may incur a large amount of taxable gain from the sale of appreciated positions. We do not accept responsibility for non-standard positions held in a client account, either transferred in or purchased at the client’s instructions, as part of our investment portfolio. We will allow these positions to be held in a non-managed account and may charge fees for such, but will not be held responsible for their performance or monitoring. Prospective clients must consider whether a particular Empirical advisory relationship is appropriate for their own circumstances based on all relevant factors including, but not limited to, the prospective client’s own investment objectives, liquidity requirements, tax situation, and risk tolerance. Prospective clients are strongly encouraged to undertake appropriate due diligence including, but not limited to, a review of governing documents and to investigate additional details about Empirical’s investment strategies, methods of analysis and related risks, before making an investment decision or committing to a service provided by Empirical. We may, on occasion, recommend that all, or a portion of your assets, be managed by an outside investment manager or sub-adviser. Sub-advisory fees are not included in Empirical’s advisory fees and may result in increased fees to the client. In all discretionary accounts, except to the extent we are directed otherwise, we are authorized to use our discretion in selecting or changing a sub-adviser and/or outside money manager without prior approval from the client. The client may be required to execute a limited power of attorney (and/or separate agreement) with the custodian, or a sub-adviser selected by us. Financial Planning Services We offer financial planning services to our advisory clients and occasionally we engage in stand-alone financial planning services to non-advisory clients. Financial planning helps clients determine and set their long-term financial goals by reviewing investments, tax planning, asset allocation, insurance and risk management, retirement planning, estate and gift planning, executive coaching, and other areas. We will meet with potential financial planning clients in advance of preparing a financial plan to determine the amount to be billed. Generally, a financial planning contract will be signed before services commence for non-advisory (stand-alone) planning clients. You may not wish to engage in the financial planning portion of our services, but for qualified advisory clients these services may be available as part of the investment advisory fee. If planning services require what Empirical considers extraordinary planning services, the client may be charged for such extraordinary planning services. What constitutes extraordinary planning will be determined on a case-by-case basis in Empirical’s sole discretion. Tax Preparation Services Empirical offers tax preparation services to both advisory and non-advisory clients. Empirical charges a separate fee (fixed or hourly) for tax preparation services, depending upon the scope and complexity of the services required. Generally, and at its sole discretion, Empirical may offer a discount on personal/individual tax preparation services to advisory clients with a minimum level of assets under management (generally above $3,000,000). These services are offered as part of our goal to provide comprehensive wealth management, but you are not obligated to use them. Estate Planning Services Empirical refers clients with estate-planning needs to Secure Legacy Law Group, P.C. (“Secure Legacy”) as well as other outside attorneys. Secure Legacy’s services include, but are not limited to, the preparation of wills, trusts, advance directives (i.e., living wills) or other health-care documents related to incapacity planning, and durable power of attorney for financial management for individuals and married couples. These services are offered as part of our goal to provide comprehensive wealth management, but you are not obligated to use them. Empirical does not serve as an attorney, and no portion of our services should be construed as offering legal services. Empirical does not prepare estate planning documents or offer legal advice. Although Empirical does not receive any compensation from Secure Legacy for referrals, Empirical’s recommendation to use estate planning services provided by Secure Legacy causes a potential conflict of interest as both firms have an economic incentive to refer clients to each other in lieu of referring clients to other law firms or financial professionals. Please refer to Item 10 – Other Financial Industry Activities Affiliations for additional information about Secure Legacy. Insurance Services Empirical, through its wholly-owned subsidiary, Empirical Insurance, LLC (“Empirical Insurance”), offers insurance-planning services specifically designed to address the life, disability, and long-term care insurance needs of our clients. Empirical Insurance can review current coverage in the context of a client’s financial plan, discuss how insurance can cover potential risks, and guide clients through the process of obtaining coverage. Empirical Insurance has access to various insurance carriers, which allows for comparison of financial strengths, costs, and product benefits of these carriers. These services are offered as part of our goal to provide comprehensive wealth management, but clients are not obligated to use them. Empirical Insurance does not charge any direct fees to its clients for the services it provides. Rather, Empirical Insurance is paid a commission upon the sale of a product that varies depending on the product sold. Our recommendation to use Empirical Insurance poses a potential a conflict of interest. Please refer to Item 10 – Other Financial Industry Activities and Affiliations for additional

information about Empirical Insurance. Real Estate Services Empirical Properties provides clients with real estate brokerage services through licensed real estate brokers. Empirical Properties offers a full spectrum of residential real estate services. Services include assisting clients with the purchase and sale of residential property, providing complimentary market analysis, review of real estate portfolio holdings and reporting, local market tracking, and cost benefit analysis of home improvement projects. Our recommendation to use Empirical Properties poses a potential conflict of interest. Please refer to Item 10 – Other Financial Industry Activities and Affiliations for additional information about Empirical Properties. Executive Consulting Services For executive consulting advisory clients, generally these services are available to you as part of your fee to Empirical so long as you maintain at least $3 million in assets under management; if you do not maintain at least $3 million in assets under management, you will pay either a quarterly or annual fee in addition to investment advisory fees. Pension Consulting Services We have a service for outside account aggregation. If you would like us to link to and make recommendations for your outside account(s) you may sign up for our aggregation service. This will allow us to have a complete view of your linked outside holdings. We will offer advice and recommendations on the outside accounts, but it will be your sole responsibility to implement allocation recommendations in these outside accounts. Empirical reserves the right to charge a fee for this service, and such fee arrangement will be provided in writing and will be deducted from your managed account. Fees will not be deducted directly from outside accounts. Pooled Investment Vehicle (Private Fund) Empirical provides discretionary portfolio management and investment advisory services to a pooled investment vehicle, Empirical Alternative Income Fund, LP (the “Fund”), whose investors are “accredited investors” as that term is defined in Regulation D, adopted pursuant to Section 4(a)(2) of the Securities Act, and “qualified clients” under SEC Rule 205-3. The Fund aims to take advantage of non-traditional investments to create a generally higher level of current income along with the opportunity for growth unrelated to public stock markets. With respect to alternative investments, clients should understand that an alternative investment strategy is subject to specific risks not associated with traditional investments and is not suitable for all investors. Alternative investments are generally classified as an investment other than a traditional stock, bond, mutual fund or exchange traded fund. Alternative investments include, but are not limited to: hedge funds, private equity funds, venture capital funds, private real estate funds, and other private investments. Investing in alternative investments is only intended for experienced and sophisticated investors who are willing to bear the high economic risk associated with such an investment. By themselves, alternative investments do not constitute a balanced investment program. The Fund is an alternative investment option made available to clients by Empirical directly through its role as the Investment Manager, and not through a third party or affiliate. The Fund is a limited partnership formed under the laws of the state of Delaware. The general partner of the Fund is PPB Empirical AIF Mgt LLC (the “general partner”). Empirical is the investment manager (the “investment manager”) of the partnership. The fund operates pursuant to the exemption from investment company registration in Section 3(c)(1) of the Investment Company Act of 1940, as amended (the “Investment Company Act”). See Item 10 – Other Financial Industry Activities and Affiliations of this Brochure for more information regarding Empirical’s affiliated entities. Clients who choose to invest in alternative investments do so based on their own independent assessment of the investment opportunity. Clients should carefully review and consider potential risks before investing, including carefully reviewing all disclosure documents, private offering memoranda, prospectuses, or other offering materials provided by Empirical and any separate manager or third-party service provider of an alternative investment. Many alternative investment offering documents are not reviewed or approved by federal or state regulators. More information about the services Empirical provides to the Fund is disclosed in Empirical’s Form ADV Part 1 and summarized in Item 7 – Types of Clients of this Brochure. In addition, Empirical’s investment philosophy and process, including portfolio construction, are more fully disclosed in Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss of this Brochure. Information about the Fund, and the particular investment objectives, strategies, restrictions, guidelines and risks associated with an investment, is described in the Fund’s governing documents, which are made available to investors only through Empirical or another authorized party. An investment in the Fund does not, in and of itself, create an advisory relationship between the investor and Empirical. Empirical may provide advisory services directly to Fund investors, but any such arrangement will be treated as any other advisory client (not invested in the Fund), to include execution of an investment advisory agreement. Retirement Accounts – Acknowledgement of Fiduciary Status under ERISA and the Code Guidance from the US Department of Labor (“DOL”) under Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“Code”), requires us to inform you that when we provide investment advice to you regarding your retirement plan or participant account or your individual retirement account (collectively retirement accounts), we are fiduciaries within the meaning of ERISA and/or the Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so for retirement accounts we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Retirement Account Rollovers When leaving an employer, you typically have four options regarding your existing retirement plan: 1. leave the assets in the former employer’s plan, if permitted, 2. roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, 3. roll over the assets to an Individual Retirement Account (“IRA”), or 4. take a full withdrawal in cash, which would result in ordinary income tax and a penalty tax if you are under age 59 1/2. If we recommend a client roll over a 401(k) or other qualified plan assets to an IRA, this rollover recommendation presents a conflict of interest in that we would receive compensation (or may increase current compensation) when investment advice is provided following a client’s decision to roll over your plan assets. We will discuss the retirement plan options including retention of the client’s 401(k) or qualified plan assets with their current plan, if allowed. Prior to deciding, clients should carefully review the information regarding their rollover options. Clients are under no obligation to rollover retirement plan assets to an account managed by Empirical.