CSPIA FORM ADV PART 2A WRAP BROCHURE DATED 03/30/2026

Cary Street Partners Investment Advisory LLC Form ADV Part 2A Wrap Fee Brochure SEC File No. 801-64239 901 East Byrd Street, Suite 1001 Richmond, Virginia 23219 https://carystreetpartners.com/ 804-340-8100 Revised March 30, 2026 This Form ADV Part 2A Wrap Brochure (“Brochure”) provides information to clients and prospective clients about the qualifications and business practices of Cary Street Partners Investment Advisory LLC (“CSPIA” or the “Firm”). If you have any questions about the contents of this Brochure, please contact us at 804-340-8100. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Cary Street Partners (“CSP”) is the trade name used by Cary Street Partners LLC (“CSP LLC”), member of the Financial Industry Regulatory Authority (“FINRA”); CSPIA and Cary Street Partners Asset Management LLC (“CSPAM”), registered investment advisers; CSPIA’s parent company, Cary Street Partners Financial LLC (“CSPF”); and CSP Parent LLC, parent company to CSPF. Registration does not imply a certain level of skill or training. The oral and written communications of an adviser provide you with the necessary information allowing you to determine whether to hire or retain an adviser. Additional information about CSPIA and our investment adviser representatives (“Financial Advisors”) is also available via the SEC’s website at www.adviserinfo.sec.gov.  Item 2 Material Changes This Brochure, dated March 30, 2026, was prepared in accordance with SEC requirements and contains both material and non-material changes from CSPIA’s last annual Wrap Brochure amendment filed on March 30, 2025 (the “Annual Update”). The following material changes have been made since the last Annual Update: • Item 4 Services, Fees, and Compensation o Added information regarding an indirect, majority owner of CSPIA, CIVC Partners Fund VII, L.P. (along with its parallel funds and affiliated investors, “CIVC Fund VII”) which became effective on May 30, 2025. Included disclosure with respect to fees CSPIA and/or an affiliate are entitled to receive. o Revised disclosure regarding Wrap Fee Programs. o o Revised disclosure with respect to revenue sharing arrangements and the conflict of interest such arrangements create. • Item 6 Portfolio Manager Selection and Evaluation: o Added disclosure with respect to certain risks o Added information regarding voting of client securities • Item 9 Additional Information o Added disclosure regarding CIVC Fund VII, a new indirect majority owner of CSPIA. We generally offer or deliver information about our qualifications and business practices to clients on at least an annual basis. Pursuant to SEC rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. As determined necessary, we will provide other ongoing disclosure information about material changes. Please contact CSPIA’s Compliance Department at (804) 340-8100 or info@carystreetpartners.com to request our Brochure, at no charge. Our Brochure is also available on our website at https://carystreetpartners.com/. March 2026 Wrap Fee Brochure Page 2 of 19  Item 3 Table of Contents Contents Item 2 Material Changes ..................................................................................................................................................... 2 Item 3 Table of Contents ..................................................................................................................................................... 3 Item 4 - Services, Fees and Compensation ..................................................................................................................... 4 Item 5 Account Requirements and Types of Clients ..................................................................................................... 10 Item 6 Portfolio Manager Selection and Evaluation ...................................................................................................... 10 Item 7 Client Information Provided to Portfolio Managers ........................................................................................... 14 Item 8 Client Contact with Portfolio Managers .............................................................................................................. 15 Item 9 Additional Information ............................................................................................................................................ 15 March 2026 Wrap Fee Brochure Page 3 of 19  Item 4 - Services, Fees and Compensation CSPIA is an SEC registered investment adviser (registered in 2005) and a limited liability company formed under the laws of, and headquartered in, the Commonwealth of Virginia. Registration does not imply a certain level of skill or training. The Firm, a wholly-owned subsidiary of CSPF, was founded in 2002, and is indirectly, majority owned by private equity fund CIVC Fund VII. See Item 9 Additional Information for additional information and CSPIA’s Form ADV, Part 1A, Schedules A and B for additional ownership information about CSPIA. As of December 31, 2025, CSPIA had $6,946,067,015 in assets under management (“RAUM”) on a discretionary basis and $3,306,197,286 in RAUM on a non-discretionary basis. This complies with the Form ADV instructions permitting RAUM to be dated within 90 days of CSPIA’s Annual Update. CSPIA provides individualized non-discretionary and discretionary advisory services to various categories of institutional and individual clients (“Clients”). See Item 5 Types of Clients. CSPIA’s advisory services include financial planning, separately managed accounts (“SMA”), and the selection of opportunities to invest in investment accounts and vehicles managed by third parties (e.g., mutual funds, other investment advisers, wrap fee programs, private equity funds, and other alternative investment vehicles). CSPIA offers advisory services on a broad spectrum of investments, including but not limited to equities, fixed income, annuities, structured notes, closed-end funds, mutual funds, and exchange-traded funds (“ETFs”). See Item 6 Portfolio Manager Selection and Evaluation for additional information about investment strategies. All services described in this Brochure begin with a consultation between you and a CSPIA representative (“Financial Advisor”) to review your investment objectives, financial situation, risk tolerance, and investment restrictions, if any (“Client Profile”). In collaboration with your Financial Advisor, you will determine which advisory services are appropriate for your needs. In performing our services, CSPIA is not required to verify any information received from the Client or from the Client’s other professionals. Clients are advised to promptly notify us if there are any changes in their Client Profile. Your Financial Advisor will provide advisory services that generally include allocation of assets among different classes, portfolio diversification, managing portfolio risk, portfolio monitoring evaluation, investment policy statement development, manager search and recommendation, financial planning, and other general economic and financial topics. Your Financial Advisor will construct an investment portfolio based on your Client Profile. All managed accounts will be maintained with an independent qualified custodian (“Qualified Custodian”). Services Offered As mentioned in CSPIA’s Form ADV 2A Firm Brochure, Financial Advisors could recommend a program or arrangement in which advisory services, trading costs, and for certain programs, other expenses are bundled (“Wrap Fee Program”). Information in this Brochure covers CSPIA’s role as Sponsor and Portfolio Manager in certain Wrap Fee Programs, as well as CSPAM’s role as Portfolio Manager in Wrap Fee Programs. Wrap Fee Programs Cary Street Partners FA Directed Wrap Program (“FA Directed Program”) CSPIA is the sponsor of the Cary Street Partners FA Directed Wrap Program which provides investment management services on a discretionary basis to each Client. This Program allows you to pay a single fee that covers advisory services, trade execution, custody, and other standard brokerage and investment services. Each Financial Advisor serves as a Portfolio Manager, developing well-diversified portfolios designed to match the Client Profile. The FA Directed Program is available through Wells Fargo Clearing Services under the Private March 2026 Wrap Fee Brochure Page 4 of 19  Investment Management Program (“PIM®”) . CSPIA is independently owned and operated and not affiliated with Wells Fargo or any other Qualified Custodian. The provisions of our FA Directed program are based on and related to certain Wrap Fee Programs offered by Wells Fargo Advisors (“WFA”). CSPIA has an agreement with WFA, pursuant to which WFA provides advisory and/or other services with respect to certain Wrap Fee Programs (“WFA Programs”) which are related to the Cary Street Partners FA Directed Program. Although WFA provides certain services to our FA Directed Program wrap clients, WFA’s policy is to have CSPIA and their other correspondent firms maintain the role of Sponsor, and in some of these programs, the Financial Advisor assumes the role of Portfolio Manager. Cary Street Partners Asset Management LLC (“CSPAM”) Wrap Programs CSPIA offers clients discretionary management services through its affiliate CSPAM, a registered investment adviser. CSPAM provides investment strategy services and is the Portfolio Manager of various Wrap Fee Programs, each sponsored by various unaffiliated, third-party registered investment advisers. Please review the CSPAM Firm Brochure (Form ADV Part 2A Firm Brochure) for a complete description of its services, fee schedules and account minimums regarding its Wrap Fee Programs. CSPAM manages specific investment strategies in Wrap Fee Programs for both non-discretionary Model and discretionary Wrap Account programs sponsored by unaffiliated financial institutions similar to its management of the same strategies implemented in its CSP Global portfolios, for example (see more on CSP Global below). In both the Wrap Account/Model programs however, CSPAM personnel primarily support the financial institution sponsoring the wrap program (“Sponsor”) and not the actual underlying Client. There are fundamental differences between a Wrap Account and Model program. In a traditional Wrap Account program, a Client selects the Sponsor. The Sponsor will work with the Client to select an approved discretionary investment adviser, like CSPAM, for a particular investment strategy. From time to time, the Sponsor will communicate any specific Client needs/requests to CSPAM, and CSPAM will evaluate for reasonableness within the strategy. CSPAM relies on the Sponsor to gather the necessary information and assess the suitability of its investment style to the individual needs and financial situation of a Wrap Account Client. For Wrap Accounts, CSPAM exercises investment discretion and delivers buy/sell instructions to the Sponsor’s platform. The Sponsor is responsible for execution of each transaction in the Client accounts. Under the Model programs, depending on the model, the Sponsor or its designated representative, sometimes referred to as an “overlay manager,” exercises investment discretion and executes each Client’s portfolio transactions based on the Sponsor’s own investment judgment. CSPAM does not tailor the model portfolio to the individual needs of any program Client. CSPAM does not evaluate suitability for clients in a Model program. In both types of wrap programs, the Sponsor provides a bundle of services for a single fee. Typically, this bundle of services includes the review and monitoring of selected investment advisers approved in the program, performance evaluation of the advisers, execution of the Client’s portfolio transactions, and custodial services for the Client’s assets and other fees that are charged in the Sponsor’s program. Depending on the Wrap Fee Program, CSPAM’s advisory fee could be included or outside of the Wrap Fee Program fee. March 2026 Wrap Fee Brochure Page 5 of 19  Other Types of Advisory Services Proprietary Investment Strategies Below is information on proprietary products offered by CSPIA’s affiliate, CSPAM. These proprietary products are either offered or relevant in FA Directed and/or CSPAM Wrap Programs. The Firm’s affiliated advisory firm, CSPAM, offers portfolio strategies focused on mutual funds, ETFs, and SMAs (“CSP Global”) or strategies utilizing individual equity and fixed income securities (“CSP Separate Accounts”). CSPAM currently serves as the investment adviser to an ETF (“CSPAM Managed ETF”). See Item 9: Additional Information for additional information about the CSPAM Managed ETF. CSP Global, CSP Separate Accounts, and the CSPAM Managed ETF are made available to Clients on a discretionary and non-discretionary basis. See Referral of Affiliated or Third-Party Investment Manager(s) for additional information with respect to CSPAM Global, CSP Separate Accounts, and the CSPAM Managed ETF. Lending Services CSPIA makes lending services (“Margin Accounts”) available to Clients through its partnership with third-party providers (e.g., Client’s Qualified Custodian) and in conjunction with our affiliate broker-dealer, CSP LLC, when applicable. Margin Accounts include: (1) lending services for the purpose of purchasing and trading in securities and effecting certain strategies (e.g., option strategies, short-selling securities) (“Margin Loans”) and (2) securities-based lending using eligible securities as collateral so Clients can access funds needed for various purposes (i.e., cannot be used to purchase, carry or trade securities, pay down margin, or for insurance products offered; can be used for various other purposes, including without limitation, home renovations, real estate purchases, tax bills, debt consolidation, private business opportunities and unexpected personal expenses) (“Non-Purpose Loans”). Qualified Custodians offer different types of Non-Purpose Loans (e.g., Securities- Backed Lines of Credit, SBLOC, Priority Credit Lines, PCLs, Pledged Asset Line or PAL, or Goldman Sachs Select, or GS Select). See Item 6 Portfolio Manager Selection and Evaluation for additional information about Margin Account risks. Clients should read all loan and credit documents carefully before opening a Margin Account. The purpose of CSPIA’s involvement with Margin Accounts is to compare available lending options for the benefit of recommending the product that is believed to be in a Client’s best interest. CSPIA and your Financial Advisor have an incentive to recommend Margin Loans as the purchase of securities in the Margin Account will result in an increase of asset-based fees which presents a conflict of interest. For certain Margin Accounts, a portion of the interest charged on the outstanding balance of your Margin Account will be paid to CSPIA and to your Financial Advisor. As a result, CSPIA and your Financial Advisor have an incentive to recommend Margin Accounts which presents a conflict of interest. Both CSPIA and CSP LLC are under common ownership and control, and at certain Qualified Custodians, CSP LLC will set the interest rates on which your Margin Account will be charged. CSPIA and your Financial Advisor have an incentive to recommend Margin Accounts and pledging the assets as collateral through CSP LLC which presents a conflict of interest. See your Margin Account disclosure documents and Fees and Compensation and Item 6 Portfolio Manager Selection and Evaluation for additional information with respect to Margin Accounts. March 2026 Wrap Fee Brochure Page 6 of 19  Fees and Compensation Wrap Fee Programs The Wrap Fee Program fee of the FA Directed Program varies and is typically negotiable. Fees are based upon a percentage of the market value of assets under management, and are generally less than or equal to 2% of the assets under management. CSPIA receives the balance of the total Wrap Fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted and shares that remaining fee with the Financial Advisor, i.e., the Portfolio Manager. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. The benefits under a Wrap Fee Program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a Wrap Fee Program is not suitable for all accounts, including, but not limited to, accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap (or bundled) fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Fee Program fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by investment advisers, broker-dealers, and custodians for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. Fees charged under the Wrap Fee Program could be higher than other investment advisers offering similar strategies. A Wrap Fee is not based directly on the number of transactions in your account. Various factors influence the relative cost of our Wrap Fee Program to you, including the cost of our investment advice, custody and brokerage execution services if you paid for them separately, the types of investments held in your account, and the frequency, type and size of trades in your account. The Wrap Fee Program could cost you more or less than purchasing our investment advice, custodial, and brokerage services separately. Our Wrap Fee Program fee covers our advisory services and the brokerage services provided by your Qualified Custodian including custody of assets, equity trades, ETFs, and agency transactions in fixed income securities. As a result, we have an incentive to execute transactions for your account with your Qualified Custodian. Our Wrap Fee Program fee does not cover all fees and costs. The fees not included in the Wrap Program fee include the following: charges imposed directly by a mutual fund, index fund, or ETF which shall be disclosed in the fund’s prospectus (i.e., fund advisory fees and other fund expenses); mark-ups and mark-downs; odd lot differentials; transfer taxes; exchange fees; certain execution fees; ADR custodial pass-through fees; spreads paid to market makers; fees (such as a commission or markup) for trades executed away from your Qualified Custodian at another broker-dealer; wire transfer fees; and other fees and taxes on brokerage accounts and securities transactions. Furthermore, WFA has separate fees such as “Platform Fees” which are not included in the Wrap Fee Program fee and also deems certain assets as “Excluded Assets,” meaning typical transaction and brokerage costs apply and are not included in the Wrap Fee Program fee. Clients should review their WFCS Client Agreement to understand the fees excluded in the Wrap Fee Program. Your Financial Advisor receives a portion of the Wrap Fee as a result of your participation in the Wrap Fee Program. The amount of this compensation could be more than what the Financial Advisor would receive if you participated in our other programs and services or paid separately for investment advise, brokerage, and other March 2026 Wrap Fee Brochure Page 7 of 19  services. Therefore, your Financial Advisor has a financial incentive to recommend the Wrap Fee Program over other programs or services. For the FA Directed Program, if cash and/or securities are added or withdrawn between billing periods, a prorated Wrap Fee Program fee will be charged or refunded on the net value of the additions and/or withdrawals as of the date of activity and will be based on the rate effective for that quarter. Wrap Fee Program fees will be assessed or refunded in the following month only if the net fee generates a fee or refund of at least $40. Other Advisory Services Fees and Revenue Sharing For most advisory services, CSPIA does not impose performance-based fees or carried interest distribution (“Performance Based Fees”). While not relevant to CSPIA’s wrap programs, there are instances where CSPIA and/or CSPIA affiliate receive Performance Based Fees. For more information, refer to CSPIA’s Form ADV 2A Firm Brochure. Referral of Affiliated or Third-Party Investment Manager(s) For Clients receiving discretionary services from their Financial Advisor, under certain circumstances your Financial Advisor will choose to utilize affiliated or third-party investment managers (“Other Investment Managers”), including investment in CSP Global, CSP Separate Accounts, or the CSPAM Managed ETF, which does not require your execution or consent. In selecting CSPAM, a conflict of interest is presented with the incentive to recommend CSPAM over third-party investment managers as CSPAM receives an advisory fee when selected. In selecting the CSPAM Managed ETF, a conflict of interest is presented as CSPAM earns higher advisory fees. Clients investing with CSPAM in CSP Global, CSP Separate Accounts, or the CSPAM Managed ETF will generally be subject to both CSPAM advisory fees and CSPIA’s Management Fee. Furthermore, CSPAM invests in the CSPAM Managed ETF in CSP Global. Clients invested in CSP Global are subject to each of CSP Global’s management fee, the CSPAM Managed ETF advisory fee, and CSPIA’s Management Fee. Certain Clients are not subject to these multiple fees. Clients can independently and directly invest in CSP Global, CSP Separate Accounts, and the CSPAM Managed ETF through other financial services firms. The receipt of additional compensation by CSPAM causes an incentive for CSPIA to invest Client assets with CSPAM and presents a conflict of interest for CSPIA. The fees charged for recommendations of Other Investment Managers and selection of CSP Global, CSP Separate Accounts, and the CSPAM Managed ETF can be higher than the fees charged by other investment advisers for similar investment advisory services. Both the description of services offered, and the assessment of fees charged by Other Investment Managers are described in disclosure documents prepared by the Other Investment Managers, such as regulatory disclosures (e.g., Form ADV Brochures, the CSPAM Managed ETF prospectus and Statement of Additional Information) and/or an investment advisory agreement with the Other Investment Manager. Lending Services Interest Charges As stated above, the Wrap Fee Program fee is based on the value of assets in a Client’s account. Using margin to purchase additional securities in an advisory account will increase the asset-based fee, with no deduction in consideration of the margin debt on the account which presents a conflict of interest. For certain Margin Accounts, a portion of the interest charged on the outstanding balances of Margin Loans will be paid to CSPIA and to your Financial Advisor. Therefore, CSPIA and your Financial Advisor have an incentive to recommend March 2026 Wrap Fee Brochure Page 8 of 19  borrowing money on a Client account, which presents a conflict of interest. See Lending Services for additional information about interest charges for Margin Accounts. Revenue Sharing CSPIA has entered revenue sharing agreements as described below (“Revenue Sharing”), and certain Financial Advisors indirectly receive Revenue Sharing payments. There is a conflict of interest for CSPIA and Financial Advisors to receive Revenue Sharing payments as it provides an incentive for CSPIA and Financial Advisors to recommend products and services for which CSPIA and/or the Financial Advisors are receiving compensation over other products and services for which additional compensation is not received. As a fiduciary, CSPIA carefully evaluates all recommended products and services and seeks to always act in the Client’s best interest above considerations for increased revenue. Summary of CSPIA Revenue Sharing Arrangements Arrangement Category Description of Revenue Shared Account-Related Fees CSPIA shares in a portion of certain account-related fees that are charged to clients, e.g., ACAT Delivery Fees, IRA termination fees, annual fees charged to accounts that do not meet waiver criteria (minimum balances, trading volume, etc.). Banking Services Fees CSPIA receives referral fees from certain banks with whom an agreement has been executed based on agreed upon rates depending on the nature of the banking services that CSPIA and Financial Advisors refer to the bank. Feeder Funds CSPIA has an arrangement with a third-party investment adviser for purposes of offering certain alternative investment products to clients. In certain offerings, advisory fees and carried interest distributions are paid to CSPIA and/or a CSPIA affiliate. Life Insurance Fees CSPIA Financial Advisors indirectly receive revenue from fixed life insurance policies; revenue originates from third-party insurance providers and is processed through CSPIA’s registered broker-dealer and registered insurance affiliate, CSP LLC. Margin Debit Balances CSPIA earns the difference between the cost of funds (i.e., the interest rate that certain Qualified Custodians charge CSPIA for funds, and the interest rate that CSPIA charges to Clients). Securities-Backed Loans CSPIA earns the difference between the cost of funds (i.e., the interest rate that certain Qualified Custodians charge CSPIA for funds, and the interest rate that CSPIA charges to Clients). Securities-Backed Loans CSPIA receives referral fees, based on the average daily principal amount of outstanding loans, accrued and paid out on a monthly basis. Referral Fees CSPIA shares a portion of revenue with promoters generally in the form of Management Fees or financial planning fees in compliance with Advisers Act requirements for endorsements and testimonials. March 2026 Wrap Fee Brochure Page 9 of 19  Cash Balances Uninvested cash balances in Client accounts, for which no interest is otherwise earned or paid, are generally automatically swept into interest-bearing deposit accounts at the Client’s Qualified Custodian ("Bank Deposit Sweep") or, if available, other sweep arrangements made available to clients (collectively "Cash Sweep Vehicles"), until these balances are invested or otherwise needed to satisfy obligations arising in connection with Client accounts. The Client generally participates in the Cash Sweep Vehicles that are available and arranged through their Qualified Custodian. These Cash Sweep Vehicles offer interest rates that are set by the Qualified Custodian, and not by CSPIA, and CSPIA has no ability to negotiate or impact the rate that is offered to Clients. The interest rates earned are sometimes below market interest rates that a Client could earn in or outside of the Cash Sweep Vehicle. Other Cash Sweep Vehicles that are available when the Qualified Custodian does not restrict other Cash Sweep Vehicles include Cash Sweep Vehicles at other Qualified Custodians and investments in money market mutual funds or similar securities. You are advised and understand that Management Fees charged on account values typically include cash balances. You should also be aware that your choice of investment of Cash Sweep Vehicle is limited by each Qualified Custodian program. Additional information about Cash Sweep Vehicles is included in each Qualified Custodian’s or alternative Cash Sweep Vehicle disclosure documentation. Item 5 Account Requirements and Types of Clients These advisory services are provided to the following types of clients: Individuals; • • Pension/Profit-sharing/Retirement Plans; • Trusts/Estates/Charitable Organizations; • Corporations and Institutions; • Governmental Entities/Educational Institutions; and • Insurance Companies. WFA imposes account minimums on the FA Directed Program that cannot be waived or negotiated, and in certain cases, the Financial Advisor will also have minimum asset size requirements as well. Item 6 Portfolio Manager Selection and Evaluation Methods of Analysis and Investment Strategies The investment strategies utilized depend on your Client Profile, as provided to us. Client portfolios are generally constructed along basic investment objective and risk tolerance categories such as: Investment Objectives Risk Tolerance Levels Growth Capital Preservation Growth and Income Conservative Income Moderate Trading and Speculation Growth Aggressive Growth Client portfolios generally include investments in companies of all sizes and in any sector, public and private, including, but not limited to, investments in energy, natural resources, distressed securities, real estate, venture March 2026 Wrap Fee Brochure Page 10 of 19  capital and buy-out, and other private equity, as well as any other business sectors or types of investments. In some cases, Financial Advisors invest in securities and financial instruments that employ hedging or other non- traditional investing techniques, such as long and short equity investing, relative value and event driven arbitrage strategies, distressed securities investing, trading and short selling strategies, opportunistic investing in global equity and fixed income investing, and specialized equity investing. When deemed appropriate, Financial Advisors choose Other Investment Advisers. In selecting Other Investment Advisers, Financial Advisors consider factors, including, but not limited to: • Strong consistent historical returns; • Well-articulated and understandable investment strategies; • Reasonable expenses; • Engage in research and fundamental analysis; • Tax efficiency; • Transparency; • Manageable downside risk; and/or • A strong cohesive team that is aligned with investor interests. See Item 4 Services, Fees, and Compensation for additional information on the selection of Other Investment Advisers and proprietary investment strategies. CSPIA uses artificial intelligence (“AI”) tools in certain aspects of its business operations and Client service activities. Current applications include: AI-assisted meeting notes and summary tools (used only with Client consent) and AI tools to support the creation of certain marketing materials, investment research, and portfolio modeling and visualization. All AI tools used by CSPIA are intended to supplement, and not replace, the judgment of CSPIA’s Financial Advisors and other investment professionals. Humans retain final decision-making authority with respect to all investment recommendations and Client-related activities. Risk of Loss CSPIA does not represent, warrant, or imply that the services or methods of analysis used can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from major losses due to market corrections or crashes. No guarantees are offered that Clients’ goals or objectives will be achieved. Further, no promises or assumptions can be made that the advisory services offered by CSPIA will provide a better return than other investment strategies. For all of the investment and market risks described here, it should be noted that investing in securities involves a risk of loss that Clients should be prepared to bear. There is no performance guarantee associated with investing in any investment strategy or security type. Certain investments are considered to be higher risk than others due to certain factors such as individual security trading liquidity, and foreign and domestic market liquidity, among other factors. Specific descriptions of certain types of risks, which you as the Client could encounter, are as follows: Artificial Intelligence Risks. The use of AI tools involves certain risks, including the risk that AI-generated outputs may be inaccurate, incomplete, or based on biased or outdated data. AI systems may also be subject to cybersecurity vulnerabilities, unauthorized access, or system failures that could affect the quality or confidentiality of information processed through such tools. CSPIA seeks to mitigate these risks through its AI Policy, which governs allowable and prohibited uses of AI at the Firm and establishes standards for human oversight of AI-generated outputs. AI use and our AI Policy is reviewed and updated periodically to reflect developments in technology, usage, and applicable regulatory guidance. March 2026 Wrap Fee Brochure Page 11 of 19  Business Disruption Risks. Business disruptions resulting from catastrophic and other material events (e.g., a pandemic) could negatively impact our ability to continue to transact business. Any significant limitation on the use of our facilities or our software applications, operating systems and networks could result in financial losses. Similar types of business disruption risks are also present for vendors and issuers of securities in which we invest, which could result in material adverse consequences for such issuers and will generally cause your investments to lose value. CSPIA maintains business continuity and disaster recovery policies and procedures, that are periodically reviewed and updated, that seek to identify and plan for potential disruptions. Concentration Risks. Certain Clients hold a relatively large concentration in a limited number of issuers, securities, industry sectors and/or geographic regions. Losses incurred in connection with such portfolios could have a material adverse effect on a Client’s overall financial condition, because the value of such portfolios will be more susceptible to any single occurrence affecting one or more of those issuers, securities, industry sectors or geographic regions than would be the case with a more diversified investment portfolio. Currency Risks. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Cybersecurity Risks. Any significant limitation on the use of our facilities or the failure or security breach of our software applications or operating systems and networks, including the potential risk of cyber-attacks, could result in the disclosure of confidential Client information and financial losses. This includes failures at vendors, custodians, broker-dealers and other service providers. CSPIA maintains policies and procedures to reduce risks related to cybersecurity. Equity Security Risks. Equity markets are volatile and impacted by liquidity and investor sentiment. Various issues impact investor sentiment and thus investors’ willingness to participate or purchase equity securities or provide liquidity to the market. Investor sentiment is impacted by economic conditions, sovereign monetary policy, political climate, world events, tax rates and other social factors. Sentiment can change rapidly causing major stock price declines in short order. It is difficult, if not impossible, to forecast these changes in sentiment and the resulting price declines. Thus, investing in stocks is a risky proposition that could result in significant losses that are not related to an individual company’s fundamentals. However, individual companies also have the potential to report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies can suffer a decline in response. These factors contribute to price volatility, which is the principal risk of investing in equity securities. Fixed Income Security Risks. Fixed income investments have similar liquidity and volatility risks of all financial assets. In addition, they have several other asset-class specific risks. Inflation risk reduces the real value of such investments as purchasing power declines on nominal dollars that are received as principal and interest. Interest rate risk comes from a rise in interest rates that causes a fixed income security to decline in price in order to make the market price-based yield competitive with the prevailing interest rate climate. Fixed income securities are also at risk of issuer default or the markets’ perception that default risk has increased. In default, either some or all the securities’ interest and principal payments will be omitted or delayed. The increase of this possibility can, in itself, cause the market price for a fixed income security to fall. CSPIA attempts to manage these risks by designing strategies that focus on fixed income diversification. The credit rating or financial condition of an issuer can affect the value of a fixed income or debt security. Generally, the lower the quality rating of a security, the greater the risk that the issuer will fail to pay interest fully and return principal in a timely manner. The issuer of an investment grade security is more likely to pay interest and repay principal than an issuer of a lower rated bond. Adverse economic conditions or changing circumstances, however, can weaken the capacity of the issuer to pay interest and repay principal. High yield or “junk” bonds are considered to be “less than investment grade” March 2026 Wrap Fee Brochure Page 12 of 19  and can be highly speculative securities that are usually issued by less creditworthy and/or highly leveraged (indebted) companies. Compared with investment grade bonds, high yield bonds can carry a greater degree of risk and can be less likely to make payments of interest and principal. Individual Security Risks. Sentiment and liquidity can create price declines or negatively impact valuation metrics. In addition, companies are faced with other fundamental risks like changes in industry, competition, lower demand for products, technological obsolescence, competitor innovation, patents, regulatory changes, political risks, cost inflation, labor relations, environmental issues, product liability and numerous other fundamental factors. Negative fundamental factors can reduce a company’s equity value. In addition, some companies also face financial risks as they are dependent on raising capital in the financial markets to fund their operations. Financial markets sometimes refuse to provide this funding. Inflation Risks. When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Rising inflation also leads to general market uncertainty. There is no guarantee that we will be able to successfully mitigate inflation risk or that interest rates will match changes in inflation rates. Interest-rate Risks. Fluctuations in interest rates can cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Liquidity Risks. Despite the heavy volume of trading in securities and futures, the markets for some securities and futures (e.g., private funds or interval funds), have limited liquidity and depth. This lack of depth could disadvantage an investor, both in the realization of the prices which are quoted and in the execution of orders at desired prices. Margin Account Risks. Margin Accounts have risks and are not suitable for everyone. For Non-Purpose Loans, if the market value of a Client’s pledged securities declines below required levels, the Client will be required to pay down their line of credit or pledge additional eligible securities in order to maintain it, or the lender could require the sale of some or all of the Client’s pledged securities. The lender will attempt to notify Clients of maintenance calls, but is not required to do so. Clients are not entitled to choose which securities in their accounts are sold. The sale of pledged securities to meet a maintenance call can also create tax liabilities and adverse tax consequences, by incurring significant capital gains on low-cost basis securities in the account. Clients should discuss the tax implications of pledging securities as collateral with their tax and legal advisors. A Non-Purpose Loan must be repaid even if the residual value of the securities in the account is insufficient. The interest rates on the Non-Purpose Loans are variable and the interest will change without prior notice to the Client, in accordance with changes in the base rate. An increase in interest rates will affect the overall cost of borrowing. All securities and accounts are subject to collateral eligibility requirements. Clients should review the statement from their Qualified Custodian for their current interest rate. An interest rate can be individually negotiated instead of based on the Qualified Custodians’ base rate, after which CSPIA or CSP LLC can change your rate, without giving you any prior notice of the change, based on factors determined by CSPIA or CSP LLC, in our sole discretion, including but not limited to the account activity and our overall business relationship. A Non-Purpose Loan has the effect of magnifying any profit or loss of the assets in the collateralized account. A Client can lose more money than deposited in the account. Market Event Risks. Some countries and regions in which CSPIA invests have experienced security concerns, outbreaks of infectious diseases, pandemics, war or threats of war and aggression, terrorism, economic uncertainty, natural and environmental disasters and/or systemic market dislocations which have led, and in the future will lead, to increased market and liquidity volatility and exchange trading suspensions and closures. March 2026 Wrap Fee Brochure Page 13 of 19  These events will likely have adverse effects on the U.S. and world economies and markets generally, each of which will likely negatively impact CSPIA’s investments and performance. Option Security Risks. Options involve risks and are not suitable for everyone. Options trading can be speculative in nature and can carry substantial risk of loss. CSPIA helps manage or mitigate the risks discussed above by selecting investment strategies, investment managers, investment structures, and individual securities within diversified portfolios, which spread security risk across numerous asset classes, companies, sectors of investment, and strategic allocation targets. Political and Regulatory Risks. The securities markets can be adversely affected by international and domestic political developments and instability, changes in government policies, tariffs, taxes, restrictions on foreign investment, currency fluctuations and changes in laws and regulations affecting portfolio companies. During periods of uncertainty, market participants could react quickly to unconfirmed reports of information leading to increased market volatility. Short Sale Risks. A short sale involves the sale of a security that a Client does not own in the expectation of purchasing the same security (or a security exchangeable therefor) at a later date at a lower price. To make delivery to the buyer, the Client must borrow the security and the Client is obligated to return the security to the lender, which is accomplished by a later purchase of the security by the Client. A short sale involves the risk of a theoretically unlimited increase in the market price of the security that would result in a theoretically unlimited loss to the Client. Structured Product Risks. Structured products (e.g., structured notes) contain higher levels of risk than other investments. Structured products come in different forms and typically consist of a debt security that is structured to make interest and principal payments based upon various assets, rates, or formulas. Investment in structured products includes significant risks including valuation, liquidity, price, credit, and market risks. One common risk associated with structured products is a relative lack of liquidity due to the highly customized nature of the investment. Moreover, the full extent of returns from the complex performance features are often not realized until maturity. As such, structured products tend to be more of a buy-and-hold investment decision, rather than a means of getting in and out of a position with speed and efficiency. Another potential risk with structured products is the credit quality of the issuer. Although the cash flows are generally derived from other sources, the structured products themselves are legally considered to be the issuing financial institution's liabilities. Clients should weigh all of these risks against any possible investment performance when investing in such structured products. Voting Client Securities For our FA Directed Program, WFA imposes the restriction which prevents CSPIA from voting proxies. CSPIA through the help of WFCS send proxies directly to you. For programs where CSPAM serves as Portfolio Manager and is responsible for proxies, see the CSPAM Form ADV Firm Brochure for CSPAM’s proxy policy procedures and guidelines. Item 7 Client Information Provided to Portfolio Managers Client information for the FA Directed are provided by the Financial Advisor through the Client Profile. Clients are advices to promptly notify us if there are any changes in their Client Profile. Client information is obtained via the Client Profile which provides information such as Client’s investment objectives, investment experience, net worth and any other details to assist the portfolio manager in managing March 2026 Wrap Fee Brochure Page 14 of 19  the account. We will only share the information necessary in order to carry out our obligations to you in servicing your account. Finally, we share your personal account data only in accordance with our privacy policy. Item 8 Client Contact with Portfolio Managers There are no restrictions on clients contacting the portfolio manager regarding changes or updates to their accounts in an FA Directed Wrap Program. Clients should contact their primary advisor or Wrap Program portfolio manager regarding changes or updates to the account. Clients are encouraged to reach out to their Financial Advisor and to provide updates to their Client Profiles. Item 9 Additional Information Disciplinary Information There are no legal or disciplinary events that would be material to a Client’s or prospective Client’s evaluation of our advisory business or the integrity of our management. Other Financial Industry Activities and Affiliations The appropriate personnel of CSPIA are registered as investment adviser representatives within their state jurisdiction and registered representatives with CSP LLC if performing broker-dealer activities on behalf of CSP. Currently, there is not a pending application for registration as a futures commission merchant, commodity pool operator, commodity trading advisor or an associated person for CSPIA or any of its affiliates or related persons described below. Cary Street Partners LLC CSP LLC is an affiliate of CSPIA and a registered broker-dealer and member of FINRA. CSP LLC is also a registered insurance entity in applicable states. CSP LLC provides investment banking, wealth management, insurance, and brokerage services to its clients. Client accounts of CSP LLC are custodied at an independent Qualified Custodian. CSP LLC and CSPF will serve, periodically, as a private placement agent for issuers of equity and debt securities. In that capacity, Financial Advisors recommend, at their discretion, certain private placements sponsored by CSP LLC to eligible Clients who are accredited investors and qualified Clients. Financial Advisers recommend, when appropriate, certain Margin Loans offered by CSP LLC that are secured by eligible marketable securities held by an independent Qualified Custodian. CSPIA and your Financial Advisor have an incentive to recommend Margin Loans as it increases CSP LLC and CSPIA’s revenues. Financial Advisors recommend, when appropriate, fixed life insurance products through CSP LLC and the Financial Advisors earn compensation for the offering of such products. See Item 4 Services, Fees, and Compensation for additional information with respect to Revenue Sharing. Luxon Insurance Services LLC Luxon Insurance Services LLC (“Luxon Insurance”) is an affiliated entity of CSPIA and a wholly owned subsidiary of CSPF. Luxon Insurance provides business insurance services to certain Clients and other entities, and is not accepting new business. Cary Street Partners Asset Management LLC As disclosed in Item 4 Services, Fees, and Compensation, CSPAM, an affiliated SEC registered investment adviser provides advisory and sub-advisory investment management services to Clients and unaffiliated SEC March 2026 Wrap Fee Brochure Page 15 of 19  registered Other Investment Advisers who have engaged with CSPAM. Registration does not imply a certain level of skill or training. In limited circumstances, CSPAM provides its services directly to Clients, but generally all services are provided through Financial Advisors, who then interact with the Client. CSPAM serves as the investment adviser to the CSPAM Managed ETF and Fairlead Strategies, an unaffiliated third party, serves as sub-adviser. See Item 4 Services, Fees, and Compensation for additional information. CIVC Partners, L.P. CSPIA is indirectly, majority-owned by CIVC Fund VII, which is managed by CIVC Partners, L.P. (“CIVC Partners”), an SEC registered investment adviser to private funds, which operates independently of CSPIA. Registration does not imply a certain level of skill or training. Additional information about CIVC Partners is available via the SEC’s website at www.adviserinfo.sec.gov. CSPIA currently does not anticipate that investment vehicles sponsored by CIVC Partners will be offered to clients. Code of Ethics, Participation or Interest In Client Transactions, and Personal Trading CSPIA is guided in all actions by the highest ethical and professional standards. CSPIA has adopted a Code of Ethics (“Code”) that affirms its duty to its Clients and applies to all officers, managers, employees, or any other person who provides investment advice on CSPIA’s behalf and subject to our supervision and control (“Supervised Persons”). The Code sets the standards of conduct to be followed by all Supervised Persons. The policies and guidelines set forth in the Code must be strictly adhered to by all Supervised Persons. Severe disciplinary actions, including dismissal, can be imposed for violations of the Code. CSPIA and our Supervised Persons have a fiduciary obligation to Clients to: • place the Clients’ interests over our own; • Comply with the Code; • Comply with applicable federal and state securities laws; and • Avoid actual or potential conflicts of interest or fully disclose them to the Client. Personal trading by Supervised Persons must be conducted in compliance with all applicable laws and procedures adopted by CSPIA. CSPIA places restrictions upon certain personnel in connection with the purchase or sale of certain personal securities transactions. CSPIA recommends to Clients that they buy or sell securities in which CSPIA and/or a related person has a material financial interest (e.g., investment vehicles in which Supervised Persons have a financial interest) which presents conflicts of interest. Policies and procedures have been designed to prevent, among other things, improper conduct where a potential conflict of interest exists with respect to any Client. A copy of CSPIA's Code will be provided to any current or prospective Client upon request by contacting CSPIA using the contact information on the cover of this Brochure. Review Of Accounts Financial Advisors and other Supervised Persons, as appropriate, will review your account and/or financial plan on a periodic basis to evaluate performance, concentration, style drift, cash flows, adherence to investment guidelines or restrictions, investment selection, asset quality, and other metrics. CSPIA, if requested, will show you how your investments compare to peers and/or relevant benchmark and provide other assessments. Upon the opening of each account, your Client Profile and strategy are reviewed for approval and consistency. Thereafter, accounts are reviewed on a transaction, monthly, quarterly or annual basis, as applicable, to monitor March 2026 Wrap Fee Brochure Page 16 of 19  the account’s performance, any individual mutual funds or securities for appropriateness, and certain restrictions that apply. Additional reviews take place during the year as requested by each Client. Each Client’s Qualified Custodian transmits a statement of account activity at least quarterly. In performing its services, CSPIA is not required to verify any information received from the Client or from the Client’s other professionals. Clients are advised to promptly notify us if there are any changes in their Client Profile. Client Referrals and Other Compensation CSPIA, as a matter of policy and practice, compensates persons (i.e., individuals or entities) for the referral of Clients, provided appropriate disclosures are made and regulatory requirements are met. Certain Qualified Custodians recommend prospective Clients to CSPIA, as an independent investment adviser. CSPIA pays these Qualified Custodian fees to receive Client referrals, including a participation fee based on the percentage of the value of the assets in the Client account and a transfer fee if the Client is transferred to another Qualified Custodian. The transfer fee presents a conflict of interest as CSPIA will incur a fee if it recommends that the Client change their Qualified Custodian. CSPIA agrees to not charge Clients referred by certain Qualified Custodians Management Fees or other costs greater than the Management fees or other costs we charge Clients with similar portfolios who were not referred through the Qualified Custodian Service at the time of referral. CSPIA, at its sole discretion, will engage in joint marketing activities with Other Investment Advisers and/or sponsors of mutual funds. These Other Investment Advisers and/or sponsors pay a portion, or all, of the cost of the activities, which payment at times takes the form of reimbursement to CSPIA. Certain Clients have other accounts with CSP LLC in which management fees are not charged. The payment of commissions in these non-managed accounts is negotiated on an entirely separate basis from the payment of advisory fees in the investment advisory accounts. See Item 4 Services, Fees, and Compensation for additional information. Financial Information CSPIA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding. March 2026 Wrap Fee Brochure Page 17 of 19  Other Information: Privacy Statement Privacy Statement WHAT DOES CARY STREET PARTNERS DO WITH YOUR PERSONAL INFORMATION? FACTS Why? What? Financial companies choose how they share your personal information. Federal laws, and certain state privacy laws, give consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. The types of personal information we collect and share depend on the product(s) or service(s) you have with us. This information can include: • Your account opening documentation, applications or other forms, which include name, address, phone number, social security number and date of birth; • Your potential or actual transactions with our affiliates, others or us; • Information, such as credit history or employment status, from non-affiliated third parties; • Information for special services offered by a third party, such as bill payment requests; and • For Investment Banking engagements, information we receive from you and your directors, officers, employees and agents about your business including its finances, technology, processes and customers. How? All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Cary Street Partners chooses to share and whether you can limit this sharing. In addition, a transfer or disclosure of customers’ personal information may occur in connection with an M&A (mergers & acquisitions) transaction, including prior to consummation of the transaction. Any such transfer or disclosure is only for purposes of integration, planning or consummation of the M&A transaction. Does Cary Street Partners share? Can you limit this sharing? yes no Reasons we can share your personal information For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders, audits, regulatory examinations, and legal investigations, or report to credit bureaus yes no For our marketing purposes - to offer our products and services to you no yes yes no yes yes yes yes, in limited circumstances* yes see note* • Contact your Financial Advisor by telephone or in-person. • Mail or email page 2 of this form using the addresses provided. • Opt-out through email notification at info@carystreetpartners.com For joint marketing with other financial companies For our affiliates' everyday business purposes - information about your transactions and experiences For our affiliates' everyday business purposes - information about your credit worthiness For our affiliates to market to you For nonaffiliates to market to you To limit our sharing or to request additional information regarding our privacy policies Please note: If you are a new customer, we can begin sharing your information for non-business purposes 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Contact your Financial Advisor or info@carystreetpartners.com Questions? *Should your Financial Advisor resign from the firm under the "Broker Protocol," we will share your name, address, phone number, account title and email address with the new firm. We also share information in limited cases for joint marketing or events. Otherwise, we do not share data with nonaffiliates March 2026 Wrap Fee Brochure Page 18 of 19  Mail-in Form Leave Blank OR if you have a joint account, your choice(s) will apply to everyone on your account unless you mark the following check box: ____ apply my choices only to me Mark any/all updates you want to limit: ____ Do not share information about my credit worthiness with your affiliates for their everyday business purposes. ____ Do not allow your affiliates or nonaffiliates to use my personal information to market to me. Name Address City, State, Zip Mail to: Cary Street Partners Operations - Privacy 901 East Byrd Street Suite 1001 Richmond, VA 23219 Account # (last 4 digits) Email to: info@carystreetpartners.com Advisor Name Who we are Who is providing this notice? Cary Street Partners - Cary Street Partners is the trade name used by Cary Street Partners LLC, Member FINRA/SIPC; Cary Street Partners Investment Advisory LLC and Cary Street Partners Asset Management LLC, registered investment advisers. What we do How does Cary Street Partners protect my personal information? • We train our employees to protect customer information. • We require independent contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us. • We continually enhance our security tools and processes. • We take steps to protect customer data and accounts by asking you for information that only you should know when you contact us. How does Cary Street Partners collect my personal information? Cary Street Partners collects non-public personal information about you from the following sources: • Your account opening documentation, applications or other forms; • Your potential or actual transactions with our affiliates, others or us; • Information, such as credit history or employment status, from non-affiliated third parties; • Information for special services offered by a third party, such as bill payment requests; and • For Investment Banking engagements, information we receive from you and your directors, officers, employees and agents about your business including its finances, technology, processes and customers. Why can't I limit all sharing? Federal law gives you the right to limit only: • Sharing for affiliates’ everyday business purposes – information about your creditworthiness; • Affiliates from using your information to market to you; • Sharing for nonaffiliates to market to you; and • State laws and individual companies may give you additional rights. Your choice will apply to everyone on your account unless you tell us otherwise or check the box at the beginning of this form. What happens when I limit sharing for an account I hold jointly with someone else? Definitions Affiliates Any other entity with common ownership and/or control with Cary Street Partners Nonaffiliates An entity that has no common ownership and/or control with Cary Street Partners Joint Marketing A formal agreement or arrangement between nonaffiliated financial companies allowing them to jointly market financial products or services to you Other Important Information California residents: We will not share information we collect about you with companies outside of Cary Street Partners, unless the law allows. For example, we share information with your consent or to service your accounts. Vermont residents: If your account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our Affiliates. March 2026 Wrap Fee Brochure Page 19 of 19