CARY STREET PARTNERS

Item 1: Cover Page Cary Street Partners Investment Advisory LLC Form ADV Part 2A Firm 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 Firm 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”), SEC registered broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”), and CSPIA and Cary Street Partners Asset Management LLC (“CSPAM”), SEC 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 Brochure amendment filed on March 30, 2025 (the “Annual Update”). The following material changes have been made since the last Annual Update: • Item 4 Advisory Business 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. o Revised disclosure regarding advisory services provided to Other Investment Advisers. o Revised disclosure regarding Wrap Fee Programs. • Item 5 Fees and Compensation: o Revised disclosure with respect to fees CSPIA and/or an affiliate are entitled to receive. o Revised disclosure with respect to revenue sharing arrangements and the conflict of interest such arrangements create. • Item 6 Performance-Based Fees and Side-By-Side Management: o Added disclosure with respect to fees CSPIA and/or an affiliate are entitled to receive, as disclosed in the fund governing documents that are provided to prospective fund investors. • Item 8 Methods of Analysis, Investment Strategies and Risk of Loss: o Added disclosure regarding investment strategies that prioritize ESG criteria over other investment criteria. o Added disclosure with respect to certain risks. • Item 10 Other Financial Industry Activities and Affiliations o Added disclosure regarding CIVC Fund VII, a new indirect majority owner of CSPIA. • Item 12 Brokerage Practices: o Revised disclosures with respect to Client Directed Brokerage Arrangements. • Other Information: o Added ERISA disclosures for Plan Fiduciaries. 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 Firm Brochure Part 2A Page 2 of 33  Item 3 Table of Contents Item 1: Cover Page ........................................................................................................................................................................1 tem 2 Material Changes ................................................................................................................................................................2 Item 3 Table of Contents ..............................................................................................................................................................3 Item 4 Advisory Business .............................................................................................................................................................4 Item 5 Fees and Compensation ..................................................................................................................................................7 Item 6 Performance-Based Fees and Side-By-Side Management ..................................................................................... 12 Item 7 Types of Clients .............................................................................................................................................................. 13 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................................................ 13 Item 9 Disciplinary Information ................................................................................................................................................. 17 Item 10 Other Financial Industry Activities and Affiliations................................................................................................... 17 Item 11 Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .................................... 19 Item 12 Brokerage Practices ..................................................................................................................................................... 19 Item 13 Review of Accounts ...................................................................................................................................................... 23 Item 14 Client Referrals and Other Compensation ................................................................................................................ 23 Item 15 Custody .......................................................................................................................................................................... 23 Item 16 Investment Discretion .................................................................................................................................................. 24 Item 17 Voting Client Securities ............................................................................................................................................... 24 Item 18 Financial Information .................................................................................................................................................... 26 Other Information: Privacy Statement ..................................................................................................................................... 27 Other Information: ERISA 408(b)(2) Disclosure ..................................................................................................................... 29 Other Information: Your Brokerage and Custody Costs with Schwab as the Qualified Custodian ................................ 32 Other Information: Qualified Custodian Class Action Policies ............................................................................................. 33 March 2026 Firm Brochure Part 2A Page 3 of 33  Cary Street Partners: Mission Statement Cary Street Partners is a wealth management firm committed to excellence in all aspects of our business. We are focused on where the industry is headed and work to get there first, challenging the status quo of old thinking and systems. We believe in individual responsibility and the power of aligning the interests of our clients, employees, owners and business partners in a culture that results in positive change and provides new opportunities. Item 4 Advisory Business 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 is a wholly-owned subsidiary of CSPF, which was founded in 2002, and is an indirect majority owned subsidiary of private equity fund CIVC Fund VII. See Item 10 Other Financial Industry Activities and Affiliations 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 regulatory 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. Services Offered CSPIA provides individualized non-discretionary and discretionary advisory services to various categories of institutional and individual clients (“Clients”). See Item 7 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 8 Methods of Analysis, Investment Strategies and Risk of Loss 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 and designation of an independent qualified custodian (“Qualified Custodian”). See Item 12 Brokerage Practices and Item 15 Custody for additional information on Qualified Custodian selection. You are responsible for periodically providing updates to your Client Profile to your Financial Advisor. Your Financial Advisor will provide advisory services that generally include allocation of assets among different classes, portfolio diversification, managing portfolio risk, portfolio monitoring and 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. March 2026 Firm Brochure Part 2A Page 4 of 33  Proprietary Investment Strategies 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 10: Other Financial Industry Activities and Affiliations 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 Item 5: Fees and Compensation for additional information with respect to CSPAM Global, CSP Separate Accounts, and the CSPAM Managed ETF. Other Investment Advisers CSPIA engages with other investment advisers to provide certain services to clients of the other investment advisers (i.e., sub-advisory services) and to serve as investment adviser to alternative products. See Item 5: Fees and Compensation, Item 6: Performance-Based Fees and Side-by-Side Management, and Item 10: Other Financial Industry Activities and Affiliations for additional information. Wrap Fee Programs In seeking to develop well-diversified portfolios aligned with Client Profiles, Financial Advisors could recommend a program or arrangement offered by CSPIA, CSPAM or a third-party sponsor (the “Wrap Fee Program Sponsor”) in which advisory services, trading costs, and for certain programs, other expenses are bundled (“Wrap Fee Program”). CSPIA serves in the role of Wrap Fee Program Sponsor for a private label Wrap Fee Program, Cary Street Partners FA Directed Program, and prepares a Wrap Fee Program Brochure with additional disclosures about the Wrap Fee Program.The benefits under a Wrap Fee Program depend, in part, upon the size of the account, the associated costs, and the frequency of securities transactions, and the type of securities transactions executed in the account. 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. With Wrap Fee Programs, the Wrap Fee Program Sponsor or other party responsible for payment of transaction fees has an incentive to reduce the frequency of securities transactions which presents a conflict of interest. Wrap Fee Programs require that all transactions be executed with the Wrap Fee Program Sponsor as a form of directed brokerage arrangement. Although, there is no charge for transactions executed by the Wrap Fee Program Sponsor, there could be circumstances that the Wrap Fee Program Sponsor determines to trade away to another broker-dealer for execution purposes. In such circumstances, the Client could pay transaction costs in addition to the Wrap Fee Program fee. See Item 12 Brokerage Practices for more information about directed brokerage arrangements. The following Wrap Fee Programs are available to Clients: (1) Cary Street Partners FA Directed Program, (2) CSPAM Wrap Fee Programs, (3) third-party Wrap Fee Programs, and (4) other pricing arrangements that are economically similar to Wrap Fee Programs (“Wrap Fee Pricing Arrangements”). See Item 5: Fees and Compensation for additional information with respect to Wrap Fee Programs and Wrap Fee Pricing Arrangements. See the Wrap Fee Program Sponsor’s Brochure for additional information about the services and fee arrangements provided in the Wrap Fee Program. Financial Planning CSPIA offers financial planning services to both prospective clients and Clients on an hourly basis, specific to mutually agreed upon analysis, specific financial planning, or comprehensive financial planning services. Your March 2026 Firm Brochure Part 2A Page 5 of 33  retirement, Financial Advisor will obtain pertinent information about you and use the information as a basis for their recommendations, which generally include, but are not limited to, topics such as insurance, tax and cash flow needs, financial planning investments, education needs, and estate planning. Such recommendations can be implemented, at your sole discretion, with the professional consultants of your choosing (including your broker-dealer, accountant, attorney, etc.). For certain financial planning services prospective clients and Clients are able to access Wealth.com, an unaffiliated third party, which provides assistance with the coordination of estate planning documents. CSPIA does not generally provide legal or accounting services, so no portion of your consultation with your Financial Advisor or use of Wealth.com should be interpreted as legal or accounting advice. Any questions regarding Wealth.com services should be addressed with Wealth.com. At a client’s request, CSPIA will provide professional references in legal, accounting, and other associated areas. See Item 10: Other Financial Industry Activities and Affiliations for additional information about independent tax services offered by a related person. Retirement Planning Services CSPIA offers advisory services for 401(k), profit sharing, non-qualified deferred compensation and retirement plans (“Retirement Plans”) that are subject to the Employee Retirement Income Security Act of 1974, as amended, (“ERISA”) and other Retirement Plans not subject to ERISA. CSPIA will serve as a “fiduciary” within the meaning of Section 3(21) of ERISA and provide non-discretionary advice with respect to the Retirement Plan, or as an “investment manager” and a “fiduciary” within the meaning of Section 3(38) of ERISA with respect to accounts in the Retirement Plan. As an Investment Manager to the Retirement Plan we will provide additional services (e.g., Investment Management, selection of Qualified Default Investment Alternatives). See Other Information: ERISA 408(b)(2) Disclosure for information on fees and conflicts of interest as it relates to CSPIA’s retirement planning services. 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 8 Methods of Analysis, Investment Strategies and Risk of Loss 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 March 2026 Firm Brochure Part 2A Page 6 of 33  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 Item 5 Fees and Compensation and Item 8 Methods of Analysis, Investment Strategies and Risk of Loss for additional information with respect to Margin Accounts. Life Insurance Strategies Your Financial Advisor will conduct an independent review of your current coverage to determine how it fits into your personal financial situation. Based on your objectives, CSPIA will work with other third-party experts to structure insurance strategies, including policies such as whole life or universal life, or fixed annuity products. See Item 5: Fees and Compensation for additional information with respect to life insurance strategies. Item 5 Fees and Compensation CSPIA typically charges an annual investment advisory fee based upon a percentage of the market value of assets placed under the Firm’s management (“Management Fee”). The fee structure can take the form of a flat, fixed, tiered or floating fee schedule, which is agreed upon by the Client and subject to certain limitations of the Qualified Custodian. The annual Management Fee is generally paid either quarterly in advance or quarterly in arrears, as described in the Client’s Investment Advisory Agreement. The Investment Advisory Agreement will include a list of specific services available to the Client and the agreed upon fee structure. Management Fees are typically deducted directly from the Client’s account but can be billed by CSPIA by invoice on request in certain instances. For accounts payable in advance, upon agreement termination, you or your respective account will receive a pro- rata refund of any prepaid, unearned fees related to the calculated fees regularly paid by you for investment management or additional services listed in your Investment Advisory Agreement. The following is a sample fee schedule provided for illustrative purposes; however, actual fee schedules will vary by Client, as disclosed in each Client’s Investment Advisory Agreement, and are negotiable. Asset Value Annualized Fee Percentage First $500,000 1.50% $500,001 - $1,000,000 1.00% $1,000,001 - $3,000,000 0.85% $3,000,001 - $5,000,000 0.75% $5,000,001 - $10,000,000 0.65% $10,000,001 - $25,000,000 0.50% $25,000,001 or more Negotiable Management Fees shown do not include the highest fee or any underlying fund or product fees, brokerage execution costs, custodian fees, or certain other expenses where applicable. At our sole discretion, we sometimes charge a reduced investment advisory fee or waive fees entirely depending on client circumstances. Due to business acquisitions and legacy agreements, fee schedules will vary among clients, and fees can be calculated in a different manner. For certain Clients, CSPIA assesses Management Fee minimums, and certain flat or fixed fee pricing arrangements exceed 2% of the total assets under management. CSPIA’s Management Fees are higher than fees charged by certain other advisers that provide the same or similar services. March 2026 Firm Brochure Part 2A Page 7 of 33  Depending on the Client relationship, we sometimes agree to “household” certain Client accounts for purposes of our Management Fee calculation. For certain accounts with Management Fees payable in advance, should eligible cash flows in excess of $100,000 in aggregate per day be added or withdrawn from an account between billing periods, a pro-rated flow fee or flow rebate, respectively, will be processed in addition to the standard quarterly fee and will be calculated based on the amount of inflows or outflows using the effective fee rate for the current quarter. No fee adjustment will be made during any fee period for appreciation or depreciation in the value of the assets in the account during that period. Wrap Fee Programs As discussed above in Item 4 Advisory Services, in Wrap Fee Programs, the Wrap Fee Program Sponsor provides a bundle of services for a single fee, generally less than 2% of assets under management. Typically, this bundle of services by the Sponsor includes the review and monitoring of selected investment advisers approved in the program, performance evaluation of the investment adviser, execution of the Client’s portfolio transactions, custodial services of the Client’s assets, payment of the advisory fee to the investment adviser, and potentially other fees charged in the Wrap Fee Program Sponsor’s program. In most cases, the Wrap Fee Program fees are negotiable. However, certain Wrap Fee Programs have household minimums that cannot be waived or negotiated. A Wrap Fee Program fee is not based directly on the number of transactions in your account. Various factors influence the relative cost of the Wrap Fee Program to you, including the cost of the investment advice, custody and brokerage execution services if you paid for them separately, the types of investments held in the account, and the frequency, type and size of trades in the account. The Wrap Fee Program could cost you more or less than paying for our investment advice, custodial, and brokerage services separately. In order to evaluate whether a Wrap Fee Program or similar arrangement is appropriate for you, you should compare the agreed-upon Wrap Fee Program fee and any other costs associated with participating in the Wrap Fee Program, if any, 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 Sponsor could be higher than other investment advisers offering similar strategies. The Wrap Fee Program fee covers our advisory services and the brokerage services provided by your Qualified Custodian. Wrap Fee Programs also include custody of assets, equity trades, and agency transactions in fixed income securities. As a result, we have an incentive to execute transactions for your account with the Wrap Fee Program Sponsor. When we trade with other broker-dealers, you will incur additional execution costs that are not included in the Wrap Fee Program fee. The Wrap Fee Program fee does not cover all fees and costs and can differ by the Wrap Fee Program. Examples of other fees not included in the wrap 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 the Wrap Fee Program Sponsor at another broker-dealer; wire transfer fees; and other fees and taxes on brokerage accounts and securities transactions. When managing a Client's account in a Wrap Fee Program , CSPIA receives as compensation for our investment advisory services, and for Wrap Fee Programs the balance of the total Wrap Fee Program fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation March 2026 Firm Brochure Part 2A Page 8 of 33  by seeking to reduce or minimize the total costs incurred in your account(s) subject to a Wrap Fee Program and to increase our Management Fee to cover these expenses. If there is limited or no trading activity in your account, we will receive more compensation from our participation in a Wrap Fee Program than if you purchased advisory services and custodian/brokerage services separately. For certain Wrap Fee Programs, 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. See Item 4 Advisory Services for additional information with respect to Wrap Fee Programs. See the Wrap Fee Program Sponsor’s Brochure, for additional information about the services and fee arrangements provided in the Wrap Fee Program. Financial Planning Financial planning fees are negotiable. We typically charge fixed fees for our financial planning services that range between $500 and $25,000, depending on the complexity and scope of services provided. We can also charge hourly fees for specific planning engagements, which would be disclosed in detail in the Client’s Financial Planning and Consulting Agreement or Investment Advisory Agreement. Your Financial Advisor may determine to include financial planning services as part of the Management Fees or to charge financial planning fees separately and/or in addition to Management Fees. Retirement Plan Services Fees for services to Retirement Plans are negotiable, including minimum and implementation fees. See Other Information: ERISA 408(b)(2) Disclosure for information on fees and conflicts of interest as it relates to CSPIA’s retirement planning services. Referral of Affiliated or Third-Party Investment Managers 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. March 2026 Firm Brochure Part 2A Page 9 of 33  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. See Item 4 Advisory Services for more information on conflicts of interest with the recommendation of proprietary strategies. Feeder Funds CSPIA offers certain funds (“Feeder Funds”) that allow for investment in other alternative investment vehicles to qualifying Clients and certain related persons. Depending on the offering, a fee paid on the basis of a share of capital gains or capital appreciation (“Performance-Based Fees”) will either be charged to the Feeder Fund and received by the Feeder Fund’s General Partner that is not affiliated with CSPIA, and/or a carried interest distribution will be paid to a CSPIA affiliate. Furthermore, there are other offering-specific fees that CSPIA will receive through Feeder Funds. In all instances, offering-specific expenses and fees are separate and in addition to your Management Fee. For certain Feeder Funds, CSPIA receives advisory fees for a specific share class of non-Client investors. Should you terminate your investment advisory relationship with CSPIA before the Feeder Fund’s liquidation, you will be moved to this share class and will be charged for the advisory fee until the Feeder Fund liquidates. Individuals that are Clients at the time of Feeder Fund closing, who remain Clients until the liquidation of the Feeder Fund, will not be responsible for the advisory fee paid to CSPIA but will be responsible for Management Fees for the assets invested in the Feeder Fund. It is important to read the Feeder Fund’s offering documents to understand all fees incurred that limit the return of your investment. See Item 4 Advisory Services, Item 6 Performance-Based Fees and Side-by-Side Management, Item 10 Other Financial Industry Activities and Affiliations, and the Feeder Fund offering documents for additional information. Lending Services Interest Charges CSPIA charges a Management Fee 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 borrowing money on a Client account, which presents a conflict of interest. See Item 4 Advisory Services for additional information about interest charges for Margin Accounts. Additional Compensation In addition to Management Fees and Performance-Based Fees paid, where applicable, to CSPIA for its advisory services, Clients are generally responsible (unless investing in a Wrap Fee Program that bundles certain fees) for securities transactions, transaction fees, mutual fund advisory fees and other expenses, advisory fees of Other Investment Advisers, custodian fees, interest, taxes and other account expenses. For variable annuities, Clients should consider charges and fees, including mortality and expense charges, administrative charges, investment management fees, and applicable 12b-1 fees. These charges and fees will reduce the value of your account and return on your investment. If you have selected a rider, or optional feature, there could be an additional cost. In addition to the annuity contract fees and expenses, you are subject to Management Fees on the terms set forth in your investment advisory agreement. This Management Fee will not be taken from the variable annuity contract. Over time, your total expenses to own a variable annuity can be greater than the total expenses to own a similar annuity not subject to Management Fees. March 2026 Firm Brochure Part 2A Page 10 of 33  Certain qualified Clients are permitted to invest in alternative investments. The Financial Advisor has discretion whether to assess a one-time fee and include the asset balance on which annualized fees are calculated. If alternative investments are billable, CSPIA will generally use the latest available market value of the alternative investments as reported to CSPIA, which are typically based on estimated figures provided by the Other Investment Adviser managing the alternative investment. In the case of ERISA accounts, the Financial Advisor is able to place orders for the execution of transactions with or through such broker-dealers or banks as are permitted under the terms of the plan and complying with Section 28(e) of the Securities Exchange Act of 1934. Transactions executed through certain broker-dealers are assessed a commission amount that could exceed the amount of commission another broker-dealer would have charged. All brokerage commissions and other costs associated with the purchase or sale of securities and other investment instruments, mutual fund or other investment fund fees, or fees of third-party investment advisers recommended by the manager, custodian fees, interest, taxes and other account expenses are the responsibility of the client and are not covered by the CSPIA’s investment management fee. Except with the prior written consent of the client and provided that the conditions of an applicable exemption under ERISA are satisfied, CSPIA shall not engage any affiliate to perform brokerage services. See Other Information: ERISA 408(b)(2) Disclosure for information on fees and conflicts of interest as it relates to CSPIA’s ERISA Retirement Plan services. Revenue Sharing CSPIA has entered revenue sharing agreements (“Revenue Sharing”), as described below, 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 Advisers indirectly receive revenue from fixed life insurance policies; revenue originates from third-party insurance providers and is March 2026 Firm Brochure Part 2A Page 11 of 33  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. 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 6 Performance-Based Fees and Side-By-Side Management For certain limited alternative investments recommended by CSPIA to qualifying Clients and certain related persons, specifically Feeder Funds discussed above in Item 5 Fees and Compensation, a Performance-Based Fee or carried interest distribution are paid to the Feeder Fund’s General Partner and/or to a CSPIA affiliate. CSPIA has an incentive to recommend alternative vehicles where a CSPIA affiliate receives Performance-Based Fees and Management Fees over other investment opportunities where a CSPIA affiliate does not receive Performance-Based Fees. Investment advisers charging Performance-Based Fees have an incentive to favor or provide more attention and service to accounts with Performance-Based Fees over accounts not paying Performance-Based Fees. For CSPIA, this conflict is mitigated in that the Performance-Based Fee is applicable to only certain Feeder Funds March 2026 Firm Brochure Part 2A Page 12 of 33  offered by CSPIA for which CSPIA is not the investment adviser allocating investment opportunities over accounts that don’t pay a Performance-Based Fee. Thus, there is no “side-by-side management” of accounts that are charged Performance-Based Fees and accounts that are not charged Performance-Based Fees. Item 7 Types of Clients CSPIA’s 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 Financial Advisors generally impose minimum asset size requirements in order to service accounts. Each Client enters into an investment advisory agreement for advisory services provided to that Client. Notwithstanding any provisions in the advisory agreement, Clients have certain non-waivable rights under federal and state securities laws and certain other laws, including but not limited to, CSPIA’s fiduciary duty to Clients as provided by the Advisers Act (Client’s “Reserved Rights”). Nothing in the investment advisory agreement shall be deemed to waive any of the Reserved Rights or any remedies afforded to the Client under federal or state securities laws. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 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 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. Some Financial Advisors construct portfolios which consider environmental, social, and governance (“ESG”) criteria. Such portfolios could include use of Other Investment Advisers, mutual funds, or other investment products and could weight ESG criteria more than other investment criteria. These investment products have disclosure documents (e.g., Form ADV Brochures, March 2026 Firm Brochure Part 2A Page 13 of 33  prospectus, etc.) which include specific information about their ESG orientation and the related risks. Clients should review such disclosure documents carefully in pursuing an ESG strategy or engaging in ESG 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 Advisory Business and Item 5 Fees and Compensation for additional information on the selection of Other Investment Advisers. 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. 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 March 2026 Firm Brochure Part 2A Page 14 of 33  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. ESG Strategy Risks. ESG strategies prioritize ESG criteria over other investment criteria. As a result, such strategies will be more limited in the number and types of investments available and may perform differently than strategies that do not screen for ESG factors. Socially responsible investing is qualitative and subjective by nature, and there is no guarantee that the criteria utilized, or judgment exercised will reflect the beliefs or values of any one particular investor. Socially responsible norms differ by region. There is no assurance that the socially responsible investing strategy and techniques employed will be successful. 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 March 2026 Firm Brochure Part 2A Page 15 of 33  to pay interest and repay principal. High yield or “junk” bonds are considered to be “less than investment grade” 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 Firm Brochure Part 2A Page 16 of 33  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. Item 9 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. Item 10 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. March 2026 Firm Brochure Part 2A Page 17 of 33  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 5 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 Advisory Services, CSPAM, an affiliated SEC registered investment adviser provides advisory and sub-advisory investment management services to Clients and unaffiliated SEC 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 5 Fees and Compensation for additional information. Other Investment Advisers CSPIA will engage with Other Investment Advisers to provide sub-advisory services and to engage Other Investment Advisers to serve as investment adviser to alternative products. See Item 4 Advisory Services and Item 5 Fees and Compensation for additional information on Other Investment Advisers. 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. Other Related Entities Maria Patton CPA, a Financial Advisor, operates an independent accounting practice. Certain Clients are clients of Maria Patton’s accounting and tax practice. These services are not supervised by CSPIA. March 2026 Firm Brochure Part 2A Page 18 of 33  Item 11 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. Item 12 Brokerage Practices How We Select and Recommend Broker-Dealers and Custodians CSPIA does not maintain custody of your assets, although we are deemed to have custody of your assets if you give us authority to withdraw assets from your account. Your assets must be maintained in an account at a Qualified Custodian, generally a broker-dealer or bank. See Item 15 Custody for additional information about custody. When, and if, CSPIA has discretion to determine the broker-dealer to be used in a securities transaction, the general policy, in conjunction with CSPIA’s duty to obtain best execution, is to select or recommend, as applicable, broker-dealers on the basis of the best combination of market price, responsiveness, financial responsibility and execution capability (considering all the factors listed above), and under the requirements of all applicable laws and regulations. Lowest possible cost is not the determinative factor. As a general policy, we will direct such brokerage transactions through broker-dealers that we reasonably believe will provide best execution given prevailing market conditions. We generally execute transactions for Clients with the Client’s designated Qualified Custodian; however, transactions are cleared through other broker-dealers when determined to be appropriate (considering the factors listed above) or requested by a Client. In addition, certain Qualified Custodians charge clients a flat dollar amount or “trade away” fee for each trade executed by a different broker-dealer. As a result, the Client could incur both the fee (commission, mark-up/mark-down) charged by the executing broker-dealer and the separate “trade away” or “step-out” fee charged by the Qualified Custodian. March 2026 Firm Brochure Part 2A Page 19 of 33  These are all considerations when selecting specific broker-dealer relationships, including Wrap Fee Programs. See Item 4 Advisory Business and Item 5 Fees and Compensation for further information. Financial Advisors recommend broker-dealers and banks to Clients to serve as the Client’s Qualified Custodian. In recommending Qualified Custodians, Financial Advisors consider a wide range of factors, including, among others: • combination of transaction execution services and asset custody services; • capability to execute, clear, and settle trades; • capability to facilitate transfers and payments to and from accounts (e.g., wire transfers, check requests, bill payment); • breadth of available investment products (e.g., equities, bonds, mutual funds, ETFs); • availability of investment research and tools that assist us in making investment decisions; • quality of services; • competitiveness of the price of those services (e.g., commission rates, margin interest rates, other fees) and willingness to negotiate the prices; reputation, financial strength, security and stability; and • • prior service to us and our Clients. Depending on the advisory services to be provided, Financial Advisors generally recommend the following independent broker-dealers: Wells Fargo Clearing Services (“WFCS”), Charles Schwab & Co. (“Schwab”), Fidelity Brokerage Services (“Fidelity”), or another Qualified Custodian. Ultimately, it is the Client’s decision to choose where to custody assets, and you, as the Client, will enter into an account agreement directly with your designated Qualified Custodian. Conflicts of interest associated with this arrangement are described below as well as in Item 5 Fees and Compensation, Item 14: Client Referrals and Other Compensation, and Other Information: Your Brokerage and Custody Costs with Schwab as Qualified Custodian. You should consider these conflicts of interest when selecting your Qualified Custodian. Conflicts of interest include, but are not limited to, the following: • Certain Qualified Custodians provide us and our Clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail Clients. However, certain retail Clients can get access to institutional brokerage services without going through us. • Certain Qualified Custodians do not charge Clients separately for custody services and are compensated by charging you commissions or other fees on trades that the Qualified Custodian executes or that settle into your account. Certain trades do not incur commissions or transaction fees. • Certain Qualified Custodians are also compensated by earning interest on the uninvested cash in your • account in a cash sweep program. In addition to commissions and other fees, certain Qualified Custodians charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that is executed by a different broker-dealer but where the securities bought, or the funds from the securities sold, are deposited (settled) into your Qualified Custodian account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, the Qualified Custodian will execute most trades for your account. Certain Qualified Custodians make available various support services. Some of those services help us manage or administer our Clients’ accounts, while others help us manage and grow our business (e.g., educational events). Such support services are generally available on an unsolicited basis (we don’t have to request them) March 2026 Firm Brochure Part 2A Page 20 of 33  and at no charge to us. These support services (e.g., investment research) service all, or a substantial number, of our Clients, including accounts not maintained at the Qualified Custodian. This creates a conflict of interest as we would have to produce or pay for certain of these services ourselves so it incentivizes us to recommend the Qualified Custodian and/or broker-dealer rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. We believe, however, that taken in the aggregate, our recommendation of a Qualified Custodian and other broker-dealers are in the best interests of our Clients. Our selection is primarily supported by the scope, quality, and price of the Qualified Custodian or broker-dealers’ services and not services that benefit only us. See Item 14 Client Referrals and Other Compensation and Other Information for Clients designating Charles Schwab & Co. as their Client Designated Broker-Dealer. Client Directed Brokerage Arrangements Clients who designate the use of a particular broker-dealer (“Client Directed Broker-Dealer”), are typically also designating the Client Directed Broker-Dealer to serve as the Client’s Qualified Custodian and should recognize that such designation has the possibility to operate to the Client's disadvantage, as under those circumstances, CSPIA will not negotiate commissions and generally will not be able to obtain volume discounts which impedes CSPIA’s ability to seek best execution. This designation can cost the Client more money. Clients can change their Client Directed Broker-Dealer at any time. A disparity in commission charges can exist between the commissions charged to Clients who with Client Directed Broker-Dealers and other clients who do not designate a Client Directed Broker-Dealer. Client Directed Broker-Dealer arrangements must be in writing and the Client will negotiate the terms and arrangements with its Client Directed Broker-Dealer, including commission rates, and we will not seek best execution from other broker-dealers. CSPIA is limited its ability to aggregate the purchase or sale of securities for Clients with a Client Directed Broker-Dealer. If possible and appropriate, CSPIA will aggregate the open orders of Clients using the same Client Directed Broker-Dealer. Soft Dollars CSPIA is authorized to pay higher prices for the purchase of securities from, or accept lower prices for the sale of securities to, brokerage firms that provide it with investment and research information, or to pay higher commissions to such brokerage firms, if we determine such prices or commissions are reasonable in relation to the overall services provided. Research services furnished by broker-dealers include written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing or appraisal services; discussions with research personnel; and invitations to attend conferences or meetings with management or industry consultants. CSPIA is not required to weigh any of these factors equally. Receipt by CSPIA of products and services provided by broker-dealers, without any cash payment by CSPIA, based on the volume of brokerage commission revenues generated from securities transactions executed through those brokers on behalf of the investment adviser’s clients is commonly referred to as “Soft Dollars.” By utilizing Soft Dollars to obtain research or other products and services, CSPIA receives a benefit because it does not have to produce or pay for such research, products or services. Any research, products or services considered for use under CSPIA's Soft Dollar policy must pass the SEC’s three-fold test: 1) Does the product or service meet the eligibility criteria for brokerage or research, as defined in Section 28(e)(3) under the Securities and Exchange Act of 1934? 2) Does the item actually provide lawful and appropriate assistance in the performance of CSPIA’s investment decision making responsibilities? 3) Has CSPIA made a good faith determination that the commissions paid are reasonable in relation to the value of the goods and services provided by the broker-dealer? These considerations are provided under Section 28(e) which provides a “safe harbor” to investment advisers with respect to potential liability for violating their duty to obtain best execution. March 2026 Firm Brochure Part 2A Page 21 of 33  All of this said, CSPIA does not currently have any formal, third-party Soft Dollar arrangements in which CSPIA is required to allocate either a stated dollar amount or stated percentage of its brokerage business to any broker- dealer for any minimum time period. As discussed above, although not a material consideration when determining whether to recommend that a client utilize the services of a particular Qualified Custodian, the Firm generally receives from certain Qualified Custodians without cost (and/or at a discount) support services and/or products certain of which assist us to better monitor and service Client accounts maintained at such institutions. Possible support services the Firm receives include: investment-related research; pricing information and market data; software and other technology that provide access to client account data; compliance and/or practice management publications; discounted or gratis consulting services; discounted and/or gratis attendance at conferences, meetings and other educational or social events; marketing support; computer hardware and/or software; or other products used by the Firm in furtherance of its investment advisory business operations. See Item 14 Client Referrals and Other Compensation for further information. Trade Errors CSPIA has implemented procedures designed to prevent trade errors; however, trade errors in Client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner that is in the best interest of the Client. In cases where the Client causes the trade error, the Client will be responsible for any loss resulting from the correction. In situations where the Client did not cause the trade error, the Client will generally be made whole and any loss resulting from the trade error will generally be absorbed by CSPIA if the error was caused by the Firm. If the error is caused by the broker-dealer or a Financial Advisor, the broker/dealer or Financial Advisor will generally be responsible for covering the costs of the error. Depending on the specific circumstances of the trade error, it is possible that the Client will not be able to receive any resulting gains. CSPIA will confer with Clients or the Financial Advisor, as appropriate, to determine if the Client should forego any gain (e.g., due to tax reasons). CSPIA will not profit from trade errors. Aggregation of Client Orders Transactions implemented for Client accounts of the same securities are generally executed for multiple clients at approximately the same time. This process is referred to as aggregating orders, bunching orders, batch trading, or block trading and is used by the Firm when it believes such action will potentially prove advantageous to clients. When we aggregate client orders, the allocation of securities among Client accounts will be done on a fair and equitable basis. Typically, the process of aggregating Client orders is done in order to achieve better execution, to negotiate more favorable commission rates, to allocate orders among Clients on an equitable basis, and to avoid differences in prices and transaction costs that might be obtained if orders were placed independently. Under this process, transactions are averaged as to price and will be allocated among Clients in proportion to the purchase and sale orders placed for each Client account on any given day. CSPIA does not receive any additional compensation as a result of aggregation. See above for limitations with respect to Client Directed Brokerage Arrangements. Class Actions CSPIA is not required to provide information regarding class action or bankruptcy claim notices, to monitor such proceedings, or file on your behalf. CSPIA is generally available to assist you with the preparation of such notices and filings upon request. Services provided to Clients regarding the monitoring and filing of class actions depend on the Qualified Custodian. Certain Qualified Custodians provide class action filing services while other Qualified Custodians do not. See Other Information: Qualified Custodian Class Action Policies for further information. March 2026 Firm Brochure Part 2A Page 22 of 33  Item 13 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 and/or annual basis, as applicable, to monitor 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. Item 14 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 5 Fees and Compensation and Item 12 Brokerage Practices for additional information. Other Information: Your Brokerage and Custody Costs with Schwab as Qualified Custodian Item 15 Custody Your Financial Advisor will recommend that you establish accounts at certain Qualified Custodians, as discussed above under Item 12 Brokerage Practices. Ultimately though, it is your decision to custody assets with one of these or another Qualified Custodian of your choosing. See Item 14 Client Referrals and Other Compensation for additional information. As a matter of policy and practice, CSPIA does not permit Supervised Persons or the Firm to accept or maintain possession or custody of Client assets. Instead, assets will be held by an independent, Qualified Custodian that March 2026 Firm Brochure Part 2A Page 23 of 33  will provide monthly or quarterly statements to the Client. Each Client must designate a Qualified Custodian, and although CSPIA does provide relevant information regarding various Qualified Custodians, Qualified Custodian selection is ultimately the Client’s decision. CSPIA urges Clients to carefully review Qualified Custodian statements, which are the official custodial records of the Client’s account. CSPIA statements or reports can vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. In certain cases, CSPIA is deemed to have custody of clients’ assets due to standing letters of authorization involving third-party recipients, being able to debit fees for our services directly from your account (when approved by you), or due to other grants of authority including serving as trustee of a Client’s trust. All trusts maintain accounts with Qualified Custodians. Where Supervised Persons are appointed as a trustee or other fiduciary position involving Clients, these trustee appointments are usually initiated on the basis of a personal or family relationship the Client has with the Supervised Person, rather than that Supervised Person’s employment with the Firm. In such circumstances, CSPIA would not be deemed to have custody. CSPIA gives instructions to the Qualified Custodian with respect to all investment decisions regarding the assets, and the Qualified Custodian is authorized and directed to effect transactions, deliver securities, make payments, and otherwise take such actions we direct. For non-discretionary accounts, we generally request documentation from you that such instructions are authorized. See Item 12 Brokerage Practices for additional information. Item 16 Investment Discretion Clients generally grants discretionary authority to CSPIA by signing an investment advisory agreement. We will have full discretionary power to supervise and direct the investments in these accounts, as long as the accounts have the same Client registration, based on your Investment Policy Statement, and any other written investment guidelines or restrictions you have provided to us. Item 17 Voting Client Securities CSPIA acknowledges it has a fiduciary obligation to its Clients that requires it to monitor corporate events and vote client proxies in cases where Clients have assigned that responsibility to the Firm. CSPIA generally votes proxies consistent with its Proxy Voting Policy. We have adopted policies and procedures reasonably designed to ensure proxies are voted in Clients’ best interests, and reasonably consistent with, wherever possible, enhancing long-term shareholder value and leading corporate governance practices. CSPIA has retained the services of Broadridge ProxyEdge (“ProxyEdge”) to vote securities on its behalf. ProxyEdge provides its Proxy Policies and Insights product. that uses data driven voting guidelines, also called the Shareholder Value Template, derived from publicly disclosed vote records of top fund families with the goal of maximizing shareholder value. CSPIA recognizes that it (1) has a fiduciary responsibility under ERISA to vote proxies prudently and solely in the best interests of Retirement Plan participants and beneficiaries and (ii) will vote proxies in the best interest of the Client (non-ERISA) when directed. Proxy Voting Guidelines CSPIA generally applies the ProxyEdge standard voting guidelines (“ProxyEdge Guidelines”). Generally, where the disclosed vote records align, routine and/or non-controversial, corporate governance issues are normally voted with management; this would include the approval of independent auditors for example. Occasionally, the ProxyEdge Guidelines vote against management’s proposal on a particular issue; such issues would generally be those deemed likely to reduce shareholder control over management, entrench management at the expense of shareholders, or in some way diminish shareholders’ present or future value. CSPIA generally March 2026 Firm Brochure Part 2A Page 24 of 33  believes that voting proxies in a manner that is favorable to a business’s long-term performance and valuation is in its Clients’ best interests. From time to time, we will receive and act upon the Client’s specific instructions regarding proxy proposals. However, such requests must be received in writing no later than 30 days in advance of the proxy voting deadline. CSPIA reserves the right to vote against any proposals motivated by political, ethical or social concerns. A complete summary of the ProxyEdge Guidelines and the Shareholder Value Template, can be requested by contacting CSPIA using the contact information on the cover of this Brochure. Conflicts of Interest Occasions arise during the voting process in which the best interests of the Clients conflict with our interests. Examples of conflicts of interest generally include (1) business relationships where CSPIA has a substantial business relationship with, or is actively soliciting business from, a company soliciting proxies and (2i) personal or family relationships whereby a Supervised Person has a family member or other personal relationship that is affiliated with a company soliciting proxies, such as a spouse who serves as a director of a public company. A potential conflict occurs if a substantial business relationship exists with a proponent or opponent of a particular initiative. If we determine that a material conflict of interest exists, CSPIA will ensure the ProxyEdge Guidelines are followed which are derived independently from CSPIA and serve to mitigate the potential for conflicts of interest. Practical Limitations Related to Proxy Voting While CSPIA makes a best effort to vote proxies, in certain circumstances it will be impractical or impossible for us to do so. Identifiable circumstances include: • Limited Value. Where CSPIA has concluded that to do so would have no identifiable economic benefit to the client or shareholder. • Unjustifiable Cost. When the costs of or disadvantages resulting from voting, in our judgment, outweigh the economic benefits of voting. • Securities Lending. If securities are on loan at the record date, the Client lending the security cannot vote the proxy. Because CSPIA generally is not aware of when a security is on loan, it will not have the opportunity to recall the security prior to the record date. • Failure to Receive Proxy Statements. CSPIA is sometimes not be able to vote proxies in connection with certain holdings, most frequently for foreign securities, if it does not receive the account’s proxy statement in time to vote the proxy. Clients can request CSPIA voted on securities held in the Client’s account free of charge, upon request. CSPIA's Proxy Voting Policy will be provided to any current or prospective Client, upon request, by contacting CSPIA using the contact information on the cover of this Brochure. In some instances, Clients have reserved the right to vote their own proxies. In such cases, CSPIA does not have the authority to vote on the Client’s behalf, and arrangements should be made by the Client to have the Qualified Custodian and/or transfer agent deliver the proxy solicitations directly to them. Wrap Fee Program sponsors’ proxy voting policies and practices differ by Wrap Fee Program. If participating in a Wrap Fee Program, Clients should review their account opening paperwork with the Qualified Custodian for information on the Program’s proxy voting process. In certain instances where Other Investment Managers are used, the Other Investment Manager could take on proxy voting responsibilities, depending on what you decide with your Financial Advisor and the agreement between CSPIA and the Other Investment Manager. March 2026 Firm Brochure Part 2A Page 25 of 33  Item 18 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 Firm Brochure Part 2A Page 26 of 33  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 businesses. 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 occurs in connection with certain M&A (mergers & acquisitions) transactions, 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 Firm Brochure Part 2A Page 27 of 33  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 Account # (last 4 digits) Mail to: Cary Street Partners Operations - Privacy 901 East Byrd Street Suite 1001 Richmond, VA 23219 Advisor Name Email to: info@carystreetpartners.com 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. What happens when I limit sharing for an account I hold jointly with someone else? Your choice will apply to everyone on your account unless you tell us otherwise or check the box at the beginning of this form. 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 Firm Brochure Part 2A Page 28 of 33  Other Information: ERISA 408(b)(2) Disclosure This disclosure is provided to the responsible plan fiduciary (“Plan Fiduciary”) of an ERISA-covered employee benefit plan (“ERISA Plans”) pursuant to ERISA Section 408(b)(2) and 29 C.F.R. § 2550.408b-2. It is intended to assist the Plan Fiduciary in determining whether the arrangement with Cary Street Partners Investment Advisory LLC (“CSPIA”) is reasonable and whether any conflicts of interest exist. This guide has been structured consistent with guidance from the Employee Benefits Security Administration, which strongly encourages covered service providers to offer plan fiduciaries a “guide,” summary, or similar tool to assist fiduciaries in identifying all disclosures required under the final rule, particularly where service arrangements and related compensation are complex and information is disclosed across multiple documents. Disclosure Description and Other Disclosure Locations Required Disclosure Category Covered Service Provider Status CSPIA provides investment advisory services to ERISA Plans and expects to receive $1,000 or more in aggregate compensation. CSPIA is therefore a “Covered Service Provider” under 29 C.F.R. § 2550.408b-2. If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client agreement in new account opening paperwork If not custodied at WFCS reference: • CSPIA Investment Advisory Agreement for Qualified Retirement Plans: Scope of Engagement Description of Services CSPIA can provide investment advisory services to ERISA Plans as an ERISA Section 3(21) or an ERISA Section 3(38) investment manager. If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client Agreement in new account opening paperwork • CSPIA Form ADV Part 2A Firm Brochure: Item 4 (Advisory Business; Retirement Planning Services) If not custodied at WFCS reference: • CSPIA Form ADV Part 2A Firm Brochure: Item 4 (Advisory Business; Retirement Planning Services) • CSPIA for Qualified Retirement Plans: Scope of Investment Advisory Agreement Engagement; Scope of Investment Services Fiduciary Status CSPIA agrees to serve as a Plan Fiduciary in the capacity (i.e., 3(21) or 3(38)) as contracted. If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client Agreement in new account opening paperwork • CSPIA Form ADV Part 2A Firm Brochure: Item 4 (Advisory Business; Retirement Planning Services) If not custodied at WFCS reference: • CSPIA Form ADV Part 2A Firm Brochure: Item 4 (Advisory Business; Retirement Planning Services) • CSPIA for Qualified Retirement Plans: Scope of Investment Advisory Agreement Engagement; Scope of Investment Services Generally, an annual fee for services is negotiable and assessed quarterly. Direct Compensation If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client Agreement in new account opening paperwork If not custodied at WFCS reference: • CSPIA Form ADV Part 2A Firm Brochure: Item 5 (Fees and Compensation; Retirement Planning Services) March 2026 Firm Brochure Part 2A Page 29 of 33  Disclosure Description and Other Disclosure Locations Required Disclosure Category • Investment Advisory Agreement for Qualified Retirement Plans: Fees (Agreement and Additional Terms and Conditions); Fee Schedule CSPIA and/or its affiliates receive compensation from third-party sources, depending on the custodian and investments selected. Indirect Compensation If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client Agreement in new account opening paperwork If not custodied at WFCS reference: • CSPIA Form ADV Part 2A Firm Brochure: Item 5 (Revenue Sharing; Additional Compensation) • Investment Advisory Agreement for Qualified Retirement Plans: Fees (Agreement and Additional Terms and Conditions); Fee Schedule Compensation Paid Among Related Parties CSPIA can select platforms, investments, and custodians where it or its affiliates receive compensation. If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client Agreement in new account opening paperwork • CSPIA Form ADV Part 2A Firm Brochure: Item 4 (Proprietary Investment Strategies); Item 5 (Referral of Affiliated or Third-Party Investment Managers; Revenue Sharing); Item 10 (Cary Street Partners LLC; Cary Street Partners Asset Management LLC) • CSPIA Form ADV Part 2A Wrap Brochure if utilizing Cary Street Partners FA Directed Strategy If not custodied at WFCS reference: • CSPIA Form ADV Part 2A Firm Brochure: Item 4 (Proprietary Investment Strategies); Item 5 (Referral of Affiliated or Third-Party Investment Managers; Revenue Sharing); Item 10 (Cary Street Partners LLC; Cary Street Partners Asset Management LLC) CSPIA’s broker-dealer affiliate, CSP LLC, does not receive brokerage commissions for executed transactions recommended by CSPIA. However, certain transaction and custodial costs are not covered by the CSPIA Management Fee and are the responsibility of the ERISA Plan. Transaction- Based Compensation If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client Agreement in new account opening paperwork • CSPIA Form ADV Part 2A Firm Brochure: Item 5 (Fees and Compensation; Retirement Planning Services; Revenue Sharing; Additional Compensation), Item 12 (Brokerage Practices) • CSPIA Form ADV Part 2A Wrap Brochure if utilizing Cary Street Partners FA Directed Strategy • If not custodied at WFCS reference: • CSPIA Form ADV Part 2A Firm Brochure: Item 5 (Fees and Compensation; Retirement Planning Services; Revenue Sharing; Additional Compensation), Item 12 (Brokerage Practices) Investment Advisory Agreement for Qualified Retirement Plans: Fees (Agreement and Additional Terms and Conditions) Either party may terminate the Agreement pursuant to the terms of the agreement. Compensation Upon Termination If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client Agreement in new account opening paperwork If not custodied at WFCS reference: • Investment Advisory Agreement for Qualified Retirement Plans: Termination (Agreement; Additional Terms and Conditions); Fee Schedule March 2026 Firm Brochure Part 2A Page 30 of 33  Disclosure Description and Other Disclosure Locations Required Disclosure Category CSPIA does not provide recordkeeping services to the ERISA Plan and receives no compensation for recordkeeping. Recordkeeping Services Advisory fees are received pursuant to the terms agreed upon in the agreement. Indirect compensation, if applicable, is received in the manner in which its described in the CSPIA Form ADV Part 2A Firm Brochure or client agreement. Manner of Receipt of Compensation If custodied at Wells Fargo Clearing Services (“WFCS”), reference: • Client Agreement in new account opening paperwork • CSPIA Form ADV Part 2A Wrap Brochure if utilizing Cary Street Partners FA Directed Strategy If not custodied at WFCS reference: • CSPIA Form ADV Part 2A Firm Brochure: Item 5 (Fees and Compensation; Revenue Sharing) • CSPIA Investment Advisory Agreement for Qualified Retirement Plans: Fees; Exhibit B (Fee Schedule) The Plan Fiduciary may request additional information regarding any disclosure herein by contacting CSPIA’s Compliance Department at (804) 340-8100 or compliance@carystreetpartners.com. Requests for Additional Information March 2026 Firm Brochure Part 2A Page 31 of 33  Other Information: Your Brokerage and Custody Costs with Schwab as the Qualified Custodian For our Clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services, but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, mutual funds and ETFs) do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. In addition to commissions and other fees, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought, or the funds from the securities sold, are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. Products and Services Available to Us from Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms, like us. They provide us and our Clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail customers can get access to institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our Clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Here is a more detailed description of Schwab’s support services: Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our Clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that Do Not Directly Benefit You: Schwab also makes available to us other products and services that benefit us, but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all, or a substantial number, of our Clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provides access to Client account data (such as duplicate trade confirmations and account statements); • Facilitates trade execution and allocates aggregated trade orders for multiple client accounts; • Provides pricing and other market data; • Facilitates payment of our fees from our Clients’ accounts; and • Assists with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events; • Consulting on technology and business needs; March 2026 Firm Brochure Part 2A Page 32 of 33  • Consulting on legal and related compliance needs; • Publications and conferences on practice management and business succession; • Access to employee benefits providers, human capital consultants, and insurance providers; and • Marketing consulting and support. Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. Certain Financial Advisors serve on certain Schwab Advisor Services’ panels such as the Client Experience Panel and the Advisory Board (collectively referred to as “Panels”). These panels consist of representatives of independent investment advisory firms who have been invited by Schwab to participate in meetings and discussions of Schwab Advisor Services’ services for independent investment advisory firms and their clients. Panel members sign nondisclosure agreements with Schwab under which they agree not to disclose confidential information shared with them. This information generally does not include material nonpublic information about the Charles Schwab Corporation, whose common stock is listed for public trading on the New York Stock Exchange (symbol SCHW). The Panel meets in person or virtually approximately twice per year and has periodic conference calls scheduled as needed. Panel members are not compensated by Schwab for their participation, but Schwab does pay for or reimburse Panel members’ travel, lodging, meals and other incidental expenses incurred in attending meetings. Schwab provides certain members of the Panel a fee waiver for attendance at certain Schwab conferences such as IMPACT. Our Interest in Schwab’s Services. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab, rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker-dealer is in the best interests of our Clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only us. Other Information: Qualified Custodian Class Action Policies WFCS Schwab and Fidelity Schwab and Fidelity do not offer class action filing services. All Clients custodied at WFCS are automatically enrolled into the class action services provided by Broadridge, WFCS’ class action vendor. With this service, Broadridge will submit claims on your behalf. If funds are recovered from a filing, Broadridge will withhold a 10% fee for their service. You are able to opt out of this service through notifying your Financial Advisor, who will work with the appropriate contacts at WFCS to stop this service. March 2026 Firm Brochure Part 2A Page 33 of 33 

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