CITY NATIONAL ROCHDALE, LLC

Part 2A of Form ADV: Firm Brochure (the “Brochure”) Item 1 – Cover Page CITY NATIONAL ROCHDALE, LLC 400 Park Avenue, 10th Floor New York, NY 10022 Telephone: Facsimile: Internet: (212) 702-3500 (212) 702-3535 www.cnr.com October 28, 2025 This Brochure provides information about the qualifications and business practices of City National Rochdale, LLC (“Adviser” or “City National Rochdale”). If you have any questions about the contents of this Brochure, please contact us by telephone at (212) 702-3500 or CNR_Compliance@cnr.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about City National Rochdale also is available on the SEC’s website at www.adviserinfo.sec.gov. Registration of an investment adviser with the SEC or with any state securities authority does not imply any level of skill or training. The advisory services described in this brochure are not insured by the Federal Deposit Insurance Corporation (FDIC); not a deposit or other obligation of, or guaranteed by, City National Bank, a national banking association, or any of its affiliates; and subject to investment risks, including possible loss of principal amount invested. Page 1  Item 2 – Material Changes There have been no material changes to the Brochure since the firm’s last Brochure update on April 24, 2025. The following changes were made for purposes of clarity. Item 1: Cover Sheet • o A named officer was removed and replaced with the general reception phone number as a point of contact. Item 17: Voting Client Securities • o A named officer was removed and replaced with the general reception phone number as a point of contact. Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................. 1 Item 2 – Material Changes ................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 3 Item 4 – Advisory Business ................................................................................................................................. 5 General Description of Advisory Firm .................................................................................................... 5 Description of Advisory Services ........................................................................................................... 5 City National Rochdale Funds ................................................................................................... 5 Asset Allocation and Consulting Services ................................................................................. 6 City National Rochdale Interval Funds ...................................................................................... 6 Third-Party Funds ...................................................................................................................... 7 Advisory Programs .................................................................................................................... 7 Affiliated Transferred-in Securities ........................................................................................... 8 Non-Managed Assets ................................................................................................................. 8 Item 5 – Fees and Compensation ....................................................................................................................... 10 A. Advisory Fees and Compensation ........................................................................................... 10 Wrap Fee Programs ................................................................................................................. 10 B. ASSET ALLOCATION PROGRAM FEE SCHEDULE: ....................................................... 13 C. Other Fees and Expenses ......................................................................................................... 14 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................... 21 Item 7 – Types of Clients ................................................................................................................................... 22 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 23 Methods of Analysis and Investment Strategies ................................................................................... 23 Material Risks (Including Significant or Unusual Risks) Relating to Investment Strategies and Types of Securities .............................................................................................................................. 26 Item 9 – Disciplinary Information ...................................................................................................................... 32 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 33 City National Bank and Royal Bank of Canada ................................................................................... 33 Non-Affiliated Investment Advisers ..................................................................................................... 33 Broker-Dealers ...................................................................................................................................... 34 Investment Companies and Pooled Investment Vehicles ..................................................................... 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................... 35 Code of Ethics ....................................................................................................................................... 35 Page 3 of 50  Client Transactions in Securities where Adviser has a Material Financial Interest ............................. 35 Item 12 – Brokerage Practices ........................................................................................................................... 37 Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions .............. 37 Investment Management Direct and Indirect Compensation ................................................... 37 Brokerage Selection ................................................................................................................. 37 Proprietary Research and Other Brokerage Services ............................................................... 38 Hard and Soft Dollar Arrangements ........................................................................................ 38 Third-Party Research Services ................................................................................................. 38 Investment Allocations ......................................................................................................................... 39 Research and Other Soft Dollar Benefits .............................................................................................. 40 Brokerage for Client Referrals .............................................................................................................. 41 Directed Brokerage ............................................................................................................................... 41 Order Aggregation ................................................................................................................................ 42 Item 13 – Review of Accounts ........................................................................................................................... 44 Frequency and Nature of Review ......................................................................................................... 44 Item 14 – Client Referrals and Other Compensation ......................................................................................... 45 Item 15 – Custody .............................................................................................................................................. 45 Item 16 – Investment Discretion ........................................................................................................................ 45 Item 17 – Voting Client Securities ..................................................................................................................... 46 Item 18 – Financial Information ......................................................................................................................... 47 Item 19 – Requirements for State-Registered Advisers ..................................................................................... 47 Item 20 – Appendix A ........................................................................................................................................ 48 CNS Investment Advisory Program Fee Schedules ............................................................................. 48 CNS Asset Allocation Program Fee Schedules .................................................................................... 50 Page 4 of 50  Item 4 – Advisory Business General Description of Advisory Firm City National Rochdale’s principal offices are located in New York, NY and Beverly Hills, CA with additional offices located in San Francisco, CA, Los Angeles, CA, Lake Mary, FL, Irvine, CA, Houston, TX, and Chicago, IL. City National Rochdale is a subsidiary of City National Bank (“CNB”). City National Rochdale and City National Bank are wholly owned subsidiaries of RBC USA Holdco Corporation, which is a wholly-owned indirect subsidiary of Royal Bank of Canada (“RBC”). Description of Advisory Services City National Rochdale has been retained by CNB and City National Securities (“CNS”) as their sub-adviser for investment advisory services. City National Rochdale provides investment advisory services generally to clients with portfolios with a minimum investment of $250,000, primarily on a discretionary basis. The client’s CNB or CNS advisor works with the client to determine their portfolio needs, investment objectives, financial position and limitations, and then coordinates with City National Rochdale to design an asset allocation and investment plan to meet their goals. Thereafter, City National Rochdale portfolio managers implement each plan, working directly with the client and their advisor, on a one-on-one basis. A typical client relationship will have a CNB or CNS advisor to assist the client through the implementation process and work with City National Rochdale for the on-going portfolio management of the client’s assets. City National Rochdale allows for customization of client portfolios. This includes working with a client’s already existing portfolio to efficiently build out what City National Rochdale believes to be an appropriate portfolio (i.e., utilizing existing securities where appropriate), managing across multiple types of accounts (IRA, trust, personal, joint, etc.), allowing clients to place certain restrictions on securities (industry, sector, etc.), types of securities (options, derivatives, etc.), and investment strategies (large cap, international, alternative, etc.), and managing a client’s portfolio in seeking to meet a client’s specific distribution needs and tax goals. City National Rochdale cannot accommodate some restrictions for client investments in underlying pooled vehicles. Except for the portion of an account that is invested in pooled vehicles, each client’s account is managed separately from other clients of City National Rochdale (i.e., securities are purchased for each client’s personal accounts). Clients can choose from a variety of programs, depending on their investment objectives, financial position and level of assets to be placed with City National Rochdale. In working with clients to implement individualized investment programs, City National Rochdale will recommend the use of various investment funds managed by City National Rochdale, its affiliates or third-party managers. City National Rochdale Funds: City National Rochdale provides investment advisory services to the City National Rochdale Funds, a Delaware statutory trust (the “Trust”) registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”), as an open-end management investment company currently offering a series of mutual funds, (the “City National Rochdale Funds”). City National Rochdale provides a continuous and regular investment program including advice regarding investment strategies, manages the City National Rochdale Funds’ investment portfolios, hires investment sub-advisers to furnish investment advice and recommendations for certain City National Rochdale Funds and provides other services necessary to Page 5 of 50  the operation of the City National Rochdale Funds. City National Rochdale provides the City National Rochdale Funds with investment management services in accordance with the investment objectives, policies and restrictions as set forth in the City National Rochdale Funds’ prospectuses and Statement of Additional Information (“SAI”). Subject to the oversight of the Trust’s Board of Trustees, City National Rochdale has discretion as to the purchase and sale of investments for the City National Rochdale Funds it directly manages, consistent with each such City National Rochdale Fund’s investment objective, policies and restrictions. City National Rochdale is responsible for the evaluation, selection and monitoring of the sub-advisers of the City National Rochdale Fixed Income Opportunities Fund, a series of City National Rochdale Funds. City National Rochdale selects sub-advisers based on a variety of factors, including investment style, performance record and the characteristics of each sub-adviser’s typical investments. The assets of the City National Rochdale Fixed Income Opportunities Fund are divided into various sleeves and City National Rochdale is responsible for allocating the assets among the sub-advisers, as well as a sleeve managed directly by City National Rochdale, in accordance with their specific investment styles. Subject to the oversight of City National Rochdale and the Trust’s Board of Trustees, the sub-advisers are responsible for providing day-to-day investment advice as to the purchase and sale of investments for these City National Rochdale Funds consistent with the applicable City National Rochdale Fund’s investment objective, policies, and restrictions. Asset Allocation and Consulting Services: City National Rochdale assists non-profit organizations, corporations and other businesses and institutional clients (other than investment companies) in formulating investment objectives and considering investment alternatives. City National Rochdale will advise clients on broad investment objectives, the selection of an investment adviser or investment program, asset allocation consulting services and monitoring a client’s portfolio investment performance. City National Rochdale will receive a fee for these services. City National Rochdale Interval Funds: City National Rochdale provides investment advisory services to the City National Rochdale Select Strategies Fund (“CNRLX”) and City National Rochdale Strategic Credit Fund (“CNROX,” and together with CNRLX, the “City National Rochdale Interval Funds”), each a Delaware statutory trust registered under the Investment Company Act of 1940 as a closed-end management investment company. City National Rochdale also offers its clients who satisfy certain suitability and eligibility requirements, as applicable, interests in the City National Rochdale Interval Funds. City National Rochdale has retained a sub-adviser for CNROX. City National Rochdale is responsible for the evaluation, selection and monitoring of the sub-adviser of CNROX. Subject to the oversight of City National Rochdale and the CNROX’s Board of Trustees, the sub-adviser is responsible for providing day-to-day investment advice as to the purchase and sale of investments for CNROX consistent with the fund’s investment objective, policies and restrictions. City National Rochdale can organize other registered and nonregistered investment funds in the future. The City National Rochdale Funds and the City National Rochdale Interval Funds are collectively referred to as the “Funds.” City National Rochdale and/or its affiliates receive fees for advisory and other services to the Funds. All Funds are subject to an annual audit by an independent auditor and audited financial statements are available upon request. As discussed more fully in Item 5, Fees and Compensation, clients who invest in the Funds will pay management fees, Rule 12b-1 fees, and/or shareholder servicing fees, as applicable to City National Rochdale and/or its affiliates, as well as other expenses of those Funds, in Page 6 of 50  addition to the City National Rochdale investment advisory fees. Some of these fees are rebated back to clients based upon client agreement and/or regulatory requirements. Third-Party Funds: City National Rochdale also offers its clients interests in non-affiliated funds registered under the Investment Company Act. City National Rochdale also offers its clients, who satisfy certain suitability and eligibility requirements, interests in other non-affiliated privately offered alternative funds that are not registered under the Investment Company Act. These funds invest in a variety of alternative investments and specialty asset classes such as European bank loans, healthcare royalty rights, rail car leasing, reinsurance bonds, and others. Clients who invest in these funds will indirectly pay the management fees and other expenses of the non-affiliated investment vehicle in addition to the City National Rochdale investment advisory fees. Advisory Programs: Advisory programs of City National Rochdale available through CNB and CNS are described below. Note that the fees and expenses associated with each program can differ (See Item 5, “Fees and Compensation,” in this Brochure). • Investment Advisory Program Customized portfolio implementation and management for clients that meet City National Rochdale’s minimum net worth requirements. The portfolio value minimum for CNB and CNS clients offered the Investment Advisory Program is $250,000. Clients pay a commission of $0.035 per share for equity security trades in all managed accounts custodied by City National Bank. • Investment Advisory Services City National Rochdale provides investment management services to CNB and CNS clients pursuant to a sub-advisory agreement. City National Rochdale receives a fee for its services. • Investment Management Indirect and Direct Compensation If CNB is engaged for a separate managed account, the account may pay commissions and securities transaction fees to the third-party broker-dealers. In addition, CNB receives indirect and direct compensation in the form of soft and hard dollar commissions that are used to pay for research and other products and services obtained from broker-dealers within the safe harbor guidelines of Section 28(e) of the Securities and Exchange Act of 1934. CNB seeks to allocate its discretionary brokerage in a manner consistent with its fiduciary obligation to obtain best execution for its clients. Transactions are not always executed at the lowest available commission. CNB may select a broker-dealer that furnishes investment research services or products, or brokerage services relating to the execution of securities transactions, resulting in a client's paying a higher commission in recognition of the value of research or brokerage services provided. In addition to execution quality, CNB may consider the value of various research services or products generating soft dollar benefits to the client. CNB has soft and hard dollar commission arrangements with the following broker-dealers: Page 7 of 50  Broker- Dealer Soft Dollar Commission per Share Hard Dollar Commission per Share Instinet SEI/SDCO $0.028 $0.0238 $0.0070 $0.0112 The investment advisory programs described above are available to Accounts maintained in the International Custody & Asset Protection Solutions program, although differing fee schedules apply (see Item 5, “Fees and Compensation,” in this Brochure). Class Actions: From time-to-time, City National Rochdale receives notices with respect to securities held or previously held in client portfolios that are subject to legal proceedings, including class actions or bankruptcies. Usually, client custodians also receive these notices and therefore generally City National Rochdale does not forward these notices to its clients or their custodians. In addition, City National Rochdale does not take legal action on behalf of or provide legal advice to clients. Where a CNR client is also a Pershing Direct client introduced through CNR Securities, LLC, and a position subject to a class action lawsuit was held at CNR during the time period specified in the class action lawsuit, the client can instruct CNR to handle the lawsuit on the client’s behalf. Where a CNR client is not a Pershing Direct client introduced through CNR Securities, LLC, CNR’s support for class action lawsuits is limited to, upon client request, providing supplemental documentation showing proof that the client held the position during a specified time period. Affiliated Transferred-in Securities If a client transfers a security to their Program Account that is affiliated with or issued or sponsored: (1) by or for RBC or an RBC affiliate (with the exception of the Affiliated Funds and RBC Funds where the conflict is otherwise mitigated), or (2) by the company where an officer, director or employee of CNR or one of CNR’s affiliates serves on the Board of Directors or Board of Trustees, the client by completing the Account Application and agreeing to the Terms and Conditions, authorizes the Advisor to sell that investment. CNR will typically liquidate the asset as soon as reasonably practicable. Please be advised that CNR cannot guarantee trade execution at a specified price. All trade executions are subject to market conditions and other circumstances. In no event will CNR be responsible for any loss related to the liquidation. If the client would prefer to continue to hold the asset, the client must notify CNR of the client’s preference at the time the asset is transferred into the account. (See Non-Managed Assets directly below regarding Non-Managed Assets and the CNR notification process.) Non-Managed Assets At the time that assets are transferred into an account, clients may direct CNR to maintain certain securities or assets as a “Non-Managed Asset”. CNS cannot hold a Non-Managed Asset in a managed account. As a result, written direction is required from the client via a Letter of Authorization expressly noting that the asset is to be maintained in a non-managed CNS brokerage account for the client. Non-Managed Assets are not part of Program portfolios as CNR cannot exercise investment discretion over or charge a management fee on Non-Managed Assets. Please speak with your CNR Advisor if you have any questions related to Non-Managed Assets. Retirement Accounts: City National Rochdale has a fiduciary duty in managing its clients’ accounts, which means that we act in our Page 8 of 50  client’s best interest in accordance with their investment objectives, financial situation and other circumstances when providing investment advice and eliminate or make full and fair disclosure of all material conflicts of interest. In addition, to the extent that City National Rochdale provides services that constitute “investment advice” to Plans or individual retirement accounts subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), City National Rochdale is a “fiduciary” as defined under Section 3(21) of ERISA or the Internal Revenue Code, as applicable. City National Rochdale also acts as a fiduciary to “Retirement Investors” under Title I of ERISA or the Internal Revenue Code (as applicable), as described under Section II(a)(1) of Department of Labor Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”). A Retirement Investor is (1) a participant or beneficiary of an employee benefit plan with authority to direct the investment of assets in his or her account or to take a distribution; (2) the beneficial owner of an IRA acting on behalf of the IRA; or (3) a fiduciary of a plan as defined under Section 3(3) of ERISA (a “Plan”) or an IRA. City National Rochdale is a fiduciary under PTE 2020-02 with respect to recommendations we make for these accounts. This means that we comply with Impartial Conduct Standards (as defined in PTE 2020-02), including a best interest standard, when providing fiduciary investment advice to clients as a Retirement Investor. Client Assets Under Management As of August 31, 2025, City National Rochdale had approximately $107 million in non-discretionary client assets under management and approximately $71.6 billion in discretionary client assets. Page 9 of 50  Item 5 – Fees and Compensation A. Advisory Fees and Compensation Following are the standard fees CNB/CNS clients pay for investment advisory services. Note that these fee schedules are the standard fee schedules used by CNB and CNS clients who use the investment management services of City National Rochdale. The fees set forth below are negotiable at the sole discretion of CNB or CNS, as applicable. Wrap Fee Programs Except as noted below, City National Rochdale is paid an asset-based fee for investment advisory and portfolio management services provided in a sub-adviser capacity for the CNS Investment Advisory Program and the CNS Asset Allocation Program (each a “Program” and collectively, the “Programs”). City National Rochdale’s sub advisory fee is generally calculated by the Programs’ Sponsor, CNS, based on a percentage of the assets under management. Program clients should review the Terms and Conditions, as well as the Wrap Fee Program Brochure of the CNS Investment Advisory Program and the CNS Asset Allocation Program regarding fees and billing arrangements. City National Rochdale does not charge Program clients or deduct fees from Program client accounts. CNS as Sponsor of the CNS Investment Advisory Program and the CNS Asset Allocation Program compensates City National Rochdale for its investment advisory services. Program fees and billing are addressed in greater detail in the respective CNS Investment Advisory Program and the CNS Asset Allocation Program Terms and Conditions and Wrap Fee Program Brochures. CNS Investment Advisory Program: The Program is known as a wrap fee program because clients pay one bundled fee to compensate CNS for portfolio management, transaction costs and custodial services. Under the Program, each client pays an asset- based fee in accordance with the Fee Schedules shown in Appendix A calculated on the daily average asset value, including cash held in the cash sweep program, and is charged monthly in arrears (the “Program Fee”). In computing the asset value of an Account, a security listed on a national securities exchange will be valued, as of the valuation date, at the closing price on the principal exchange on which it is traded. Any other security in an Account will be valued in a manner determined by the Sub-Advisor or its agents in good faith to reflect fair market value. The Sub-Advisor may rely on valuations furnished by Program vendors and/or their independent pricing services. For the purpose of calculating the Program Fee, the first month will commence on the first calendar month after the effective date of the Fee Schedule. The Client’s initial Program Fee payment will be due at the end of the calendar month wherein the Account was opened. The Program Fee charged will be prorated for the period from the Account opening date through the last day of the calendar month. Thereafter, Program Fees will continue to be charged monthly in arrears and will cover each subsequent calendar month in its entirety. Clients authorize CNB and Schwab as custodians to deduct the Program Fees from their Custodial Account. In the event the Terms and Conditions are terminated by either party prior to the end of the billing period, a pro- rata refund of the Program Fee will be made by CNS to the client. A wrap fee program may not be the lowest cost option if you would like to restrict your investments to open- end mutual funds or other long-term investment products. Clients should also note that the Program Fee does Page 10 of 50  not include certain other fees and expenses. See “Other Fees and Expenses” below for more information. CNS Asset Allocation Program: The Program is known as a wrap fee program because clients pay one bundled fee to compensate CNS for portfolio management, transaction costs and custodial services. Under the Program, each client pays an asset- based fee in accordance with the Fee Schedules shown in Append A calculated on the market value of the assets in the Account determined as of the close of business on the last business day of the calendar quarter (the “Program Fee”). In computing the asset value of an Account, a security listed on a national securities exchange will be valued, as of the valuation date, at the closing price on the principal exchange on which it is traded. Any other security in an Account will be valued in a manner determined by the Sub-Advisor or its agents in good faith to reflect fair market value. The Sub-Advisor may rely on valuations furnished by Program vendors and/or their independent pricing services. The Program Fee for each quarter is paid in advance and will be calculated at one fourth (⅟4) of the rates set forth in the Fee Schedules. For the purpose of calculating the Program Fee, the first quarter will commence on the first calendar quarter after the effective date of the Fee Schedule. The Client’s initial Program Fee payment will be due at the end of the calendar quarter wherein the Account was opened. The Program Fee charged will be prorated for the period from the Account opening date through the last day of the calendar quarter. Thereafter, Program Fees will be charged quarterly in advance and will cover each subsequent calendar quarter in its entirety. Clients authorize NFS as custodian to deduct the Program Fees from their Custodial Account. In the event the Terms and Conditions are terminated by either party prior to the end of the billing period, a pro- rata refund of the Program Fee will be made by CNS to the client. A wrap fee program may not be the lowest cost option if you would like to restrict your investments to open- end mutual funds or other long-term investment products. Clients should also note that the asset-based fee for the Program Fee does not include certain other fees and expenses. See “Other Fees and Expenses” below for more information. Program Fees are negotiable in certain circumstances and may differ from client to client based upon a number of factors, including the amount of the assets, the client-related services to be provided to the Account, the overall relationship with CNS and its affiliates and other relevant criteria. Program Fees may also differ as a result of the application of prior fee schedules depending upon a client’s Program inception date. The prospectus of each City National Rochdale Fund advised by City National Rochdale sets forth the applicable fees and expenses. See Item 5.E. below regarding Conflicts related to the mutual and interval funds. A description of the calculation and payment of fees payable to City National Rochdale and its affiliates is presented in the respective Fund’s prospectus, SAI or offering document. Clients should refer to such documents for further information with respect to fees. Page 11 of 50  INVESTMENT MANAGEMENT Annual Fees on Market Value: Assets under Management: 1.25% on the first ...................................................................................................................... $1,000,000 1.00% on the next ..................................................................................................................... $4,000,000 0.75% on the next ..................................................................................................................... $5,000,000 0.50% in excess of ...................................................................................................................$10,000,000 Account Minimums: Minimum Annual Fee ...................................................................................................................... $3,000 Minimum Annual Fee for certain negotiated mandates ……………………………............................................................................................$12,500 City National serves as Trustee………………………………………Additional 0.25% on the first $10M CONSERVATIVE GROWTH & INCOME Annual Fees on Market Value: Assets under Management: 0.80% on the first ...................................................................................................................... $1,000,000 0.65% on the next ..................................................................................................................... $4,000,000 0.40% on the next ..................................................................................................................... $5,000,000 0.30% in excess of ...................................................................................................................$10,000,000 Account Minimums: Minimum Annual Fee ...................................................................................................................... $3,000 Minimum Annual Fee for certain negotiated mandates…………………………………………..$10,000 City National serves as Trustee………………………………………Additional 0.25% on the first $10M FIXED INCOME Annual Fees on Market Value: Assets under Management: 0.50% on the first ...................................................................................................................... $5,000,000 0.40% on the next ..................................................................................................................... $5,000,000 0.30% on excess of ................................................................................................................. $10,000,000 Minimum Annual Fee: Investment Type Investment Strategy Minimum Fee Taxable/Tax-Exempt Multi Strategy $3,000 Taxable Short-term Intermediate $3,000 Page 12 of 50  Tax-Exempt Short-term Intermediate $6,000 Taxable/Tax-Exempt $6,000 Intermediate - Standard Taxable/Tax-Exempt Any Strategy - Customized $12,000 $10,000 City National serves as Trustee Trustee Fee Additional 0.25% on the first $10M LIQUIDITY MANAGEMENT Liquidity Management Fee Schedule Taxable/Tax-Exempt Strategy - Annual Fees on Market Value 0.15% on the first 0.10% on the next 0.08% in excess of AUM $10,000,000 $10,000,000 $20,000,000 Minimum annual fee: Minimum account size: $7,500 $5,000,000 B. ASSET ALLOCATION PROGRAM FEE SCHEDULE: Investment Management Annual Fees on Market Value Assets Under Management 1.25% on the first: $1,000,000 1.00% on assets over: $1,000,000 $500 Minimum Annual Fee: Transaction Fees: Equities and Exchange-Traded Funds .................................................................................................. $3.50 Disbursements: Check........................................................................................................................................................ $5.00 Wire.........................................................................................................................................................$15.00 Page 13 of 50  IRAs: Additional Fees: Annual Maintenance .....................................................................................................................$35.00 Termination Fee ..........................................................................................................................$125.00 ASSET ALLOCATION PROGRAM FEE SCHEDULE: DIVERSIFIED FIXED INCOME & CONSERVATIVE GROWTH & INCOME STRATEGY Annual Fees on Market Value Assets Under Management 0.80% on the first: $1,000,000 0.65% on assets over: $1,000,000 $500 Minimum Annual Fee: Transaction Fees: Equities and Exchange-Traded Funds................................................................................................ $3.50 Disbursements: Check……………………………………………………………………………………..………….$5.00 Wire…………………………………………………………………………………………………$15.00 IRAs: Additional Fees: Annual Maintenance………………………………………………………………………………... $35.00 Termination Fee…………………………………………………………………………………….$125.00 C. Other Fees and Expenses Pershing Cash Sweep For accounts custodied at Pershing, City National Rochdale will automatically sweep cash balances into non-affiliated money market funds available to those accounts custodied at Pershing (“Sweep Fund”). City National Rochdale receives compensation as part of a revenue sharing arrangement for City National Rochdale client assets invested in the Sweep Funds. Interest rates received on Sweep Funds generally are lower than the interest rates available if clients make deposits directly with a bank or other depository institution or invests other money market funds or cash equivalents. SEI Managed Account Sweep The first $250,000 goes to the CNB Deposit and assets over $250,000 go to the CNR Government Money Market Fund – Servicing Class: CNR Govt MMF – Servicing Class, there is a 25-basis points shareholder servicing fee which goes to CNB or CNS Page 14 of 50  CNB Deposit - CNB pays CNS/Wealth Management effective fed funds (EFF) + 25-basis points and which goes on the CNS or Wealth Management financials. Affiliated Transferred-in Securities If a client transfers a security to their Program Account that is affiliated with or issued or sponsored: (1) by or for RBC or an RBC affiliate (with the exception of the Affiliated Funds and RBC Funds where the conflict is otherwise mitigated), or (2) by the company where an officer, director or employee of CNR or one of CNR’s affiliates serves on the Board of Directors or Board of Trustees, the client by completing the Account Application and agreeing to the Terms and Conditions, authorizes the Advisor to sell that investment. CNR will typically liquidate the asset as soon as reasonably practicable. Please be advised that CNR cannot guarantee trade execution at a specified price. All trade executions are subject to market conditions and other circumstances. In no event will CNR be responsible for any loss related to the liquidation. If the client would prefer to continue to hold the asset, the client must notify CNR of the client’s preference at the time the asset is transferred into the account. (See Non-Managed Assets directly below regarding Non- Managed Assets and the CNR notification process.) Non-Managed Assets At the time that assets are transferred into an account, clients may direct CNR to maintain certain securities or assets as a “Non-Managed Asset”. CNS cannot hold a Non-Managed Asset in a managed account. As a result, written direction is required from the client via a Letter of Authorization expressly noting that the asset is to be maintained in a non-managed CNS brokerage account for the client. Non-Managed Assets are not part of Program portfolios as CNR cannot exercise investment discretion over or charge a management fee on Non- Managed Assets. Please speak with your CNR Advisor if you have any questions related to Non-Managed Assets. Mutual Fund and Interval Fund Fees and Compensation: investment management, City National Rochdale will recommend the following City National Rochdale Funds (collectively, the “Affiliated Funds”) in the chart below for an Account if they are appropriate, unless the client requests otherwise. City National Rochdale believes the Affiliated Funds are appropriate investments because they offer a wide variety of investment strategies and objectives and provide professional investment diversification, and convenience. When City National Rochdale buys shares of Affiliated Funds for an account, City National Rochdale earns a management fee, City National Rochdale and/or its affiliates receive shareholder servicing fees, and its affiliates also earn distribution (12b-1) fees. Using Affiliated Funds presents City National Rochdale with a conflict of interest because City National Rochdale could buy similar unaffiliated funds for an Account that does not pay management fees, 12b-1 fees, shareholder servicing fees, or all of them, to City National Rochdale or its affiliates. Those unaffiliated funds sometimes have lower overall fees than similar Affiliated Funds. Some of the Affiliated Funds have share classes that do not charge distribution (12b-1) fees, but those share classes are not available to City National Rochdale clients in advisory programs of City National Rochdale. They are available only to CNS clients in the CNS Asset Allocation Program in relation to the Government Money Market Fund; CNS clients in the CNS Investment Advisory Program; and CNR clients whose accounts are maintained at CNB, advised by CNB or CNS, and sub- advised by CNR. City National Rochdale mitigates its conflict of interest by rebating all of City National Rochdale’s portion of the fund-level management fees and distribution (12b-1) fees for the Affiliated Funds for all client Accounts in advisory programs, as shown in the Affiliated Fund Fee Table below. Page 15 of 50  City National Rochdale rebates its portion of Affiliated Fund management fees and distribution (12b-1) fees on a quarterly basis in arrears for all client Accounts in advisory programs, The Affiliated Fund share classes utilized in the CNS Investment Advisory Program do not charge a distribution (12b-1) fee and; therefore, there is not a distribution (12b-1) fee rebate for CNS Investment Advisory Program client Accounts. CNR will provide advance notification of any changes in the Affiliated Funds management fee rebate schedule. Distribution (12b-1) Fees: Distribution (12b-1) fees compensate CNB, CNS and CNR Securities, LLC (“CNR Securities”), City National Rochdale’s affiliated broker-dealer, for paying their own personnel who are involved in distribution-related activities with respect to the Affiliated Funds. CNS and CNR Securities also use distribution (12b-1) fees they receive to pay other broker-dealers who sell Fund shares. These and other fees are described in greater detail in the Funds’ prospectus or offering documents. These fees directly benefit CNB, CNS and CNR Securities. Shareholder Servicing Fees Shareholder servicing fees compensate City National Rochdale, CNB and CNS for responding to shareholder inquiries; processing shareholder purchases and redemptions; performing shareholder account maintenance; sending Fund proxies, annual reports and other correspondence to shareholders; and providing office space, equipment, facilities and personnel to provide these services. These and other fees are described in greater detail in the Funds’ prospectuses, SAIs or other offering documents. City National Rochdale and/or its affiliates retain the shareholder servicing fees received from Affiliated Funds, with the exception of ERISA and other tax-deferred retirement accounts invested in the City National Rochdale Interval Funds, which are rebated entirely. Page 16 of 50  AFFILIATED FUND FEE TABLE City National Rochdale Funds Shareholder Servicing Fee Distribution (12b-1) Fee Fund Management Fee Fund Management Fee Rebate Shareholder Servicing Fee Rebate Distribution (12b-1) Fee Rebate 100% 0.25% N/A None N/A 0.26%1 Government Money Market Fund – Servicing Class 100%4 0.25% N/A 0.25% 100% 0.50%3 Fixed Income Opportunities Fund – Class N6 0.40% 100% 0.25% N/A None N/A U.S. Core Equity Fund – Servicing Class 100% 0.25% 100%5 None N/A 0.50%2 Select Strategies Fund – Class Y 100%4 0.25% 100%5 None N/A 1.50%2,3 Strategic Credit Fund – Class Y 1 City National Rochdale (the Fund’s investment adviser (Adviser) has contractually agreed to waive its management fee for the Government Money Market Fund such that the fee charged is 0.15% through January 31, 2026. Prior to that date, the arrangement may be terminated without penalty (a) by the Fund’s Board of Trustees, or (b) by the Adviser effective no earlier than January 31, 2026, upon at least 60 days’ prior written notice. Management fees waived by the Adviser pursuant to this arrangement will not be eligible for reimbursement by the Fund to the Adviser. 2 The Adviser has contractually agreed to waive its management fee and/or reimburse expenses to the extent necessary to ensure that the Select Strategies Fund’s total annual operating expenses will not exceed 1.00% and the Strategic Credit Fund’s total annual operating expenses will not exceed 1.95% (after fee waivers and/or expense reimbursements, and exclusive of front-end or contingent deferred loads, taxes, interest, brokerage commissions, acquired fund fees or expenses, extraordinary expenses such as litigation expenses, and other expenses not incurred in the ordinary course of the respective Fund’s business). These arrangements will continue until July 27, 2025 for the Select Strategies Fund and until October 1, 2025 for the Strategic Credit Fund, and will automatically renew for an additional one-year period unless sooner terminated by the respective Fund or by the Fund’s Board of Trustees upon 60 days’ written notice to the Adviser or termination of the advisory agreement between the Fund and the Adviser. The Adviser may recoup fees waived and expenses reimbursed for a period of three years following the date such reimbursement or reduction was made if such recoupment does not cause current expenses to exceed the expense limit for the respective Fund in effect at the time the expenses were paid/waived or any expense limit in effect at the time of recoupment. 3 Sub-advised Fund – The Fund Management Fee reflected in the table above is the total management fee paid by the Fund. The management fee received by City National Rochdale and Affiliates is lower. If applicable per fee schedule, only the amount received by City National Rochdale is rebated to the Account. 4 The Management Fee Rebate percentage reflected in the table above is applied against the net fee (net of fees paid to third party sub-advisers) paid by the Fund to City National Rochdale. Management Fees paid to third party sub-advisers are not rebated by City National Rochdale. 5 The Shareholder Servicing Fee for the Select Strategies Fund and the Strategic Credit Fund is rebated only for all ERISA qualified and other tax- deferred retirement accounts. 6Class N shares of the Fixed Income Opportunities Fund are utilized because the Servicing Class shares are not available for purchase. Periodically, City National Rochdale and/or RBC will add new/additional funds to the Affiliated Funds offering. At the time an account is invested in one of these additional funds, City National Rochdale will notify the client of its intent to add the fund and will deliver the fund’s prospectus or summary prospectus to the client. Failure to object will be treated as consent to the investment in the new fund. You can terminate your approval for these additional funds by notifying City National Rochdale in writing within the time stated in CNR’s notification. Additionally, City National Rochdale may remove current Affiliated Funds. City National Rochdale may do so in its sole discretion and without providing prior notice. City National Rochdale’s affiliated broker-dealer, CNR Securities, LLC, will also receive miscellaneous fees for transactions effected in the City National Rochdale Funds, City National Rochdale Interval Funds, and RBC Funds. Clients should be advised that City National Rochdale’s affiliated broker-dealer, CNR Securities LLC, will receive miscellaneous fees for transactions effected in the Affiliated Funds. In addition, City National Rochdale has an incentive to invest client assets in products of sponsors and fund managers that share their revenue with us, including our affiliate RBC and other third parties, over other products of sponsors or fund managers that do not share their revenue or who share less. City National Rochdale has a conflict of interest in earning more fees for itself and its Page 17 of 50  affiliates. City National Rochdale mitigates this conflict by crediting these revenue sharing payments to all client accounts in advisory programs as reflected above. For additional information on the fees City National Rochdale or its related persons receive for services to the Affiliated Funds, see Item 10 – Other Financial Industry Activities and Affiliates, and Item 12 – Brokerage Practices. Conflicts of Interest for Purchases of Affiliated Funds City National Rochdale has discretion to purchase Affiliated Funds for clients. City National Rochdale earns management fees from Affiliated Funds, City National Rochdale and/or its affiliates earn shareholder servicing fees from Affiliated Funds and City National Rochdale’s brokerage affiliates receive 12b-1 fees from Affiliated Funds. City National Rochdale at times will recommend or buy for clients Affiliated Funds for client’s accounts, even when similar unaffiliated funds charge lower fees. City National Rochdale’s and its affiliates’ receipt of these fees is a conflict of interest. While City National Rochdale seeks to give clients unbiased, objective investment advice about the selection of funds and share classes for its clients, it also has an interest in earning more fees for itself and its affiliates by recommending or buying for clients Affiliated Funds. City National Rochdale seeks to mitigate this conflict by crediting some fees to clients, with a few exceptions, as discussed above in “Mutual Fund and Interval Fund Fees and Compensation.” Because City National Rochdale and/or its affiliates retain at least some of these fees, City National Rochdale continues to have a conflict of interest in recommending or buying Affiliated Funds for an Account. In addition to the fee rebate practices discussed above, City National Rochdale seeks to mitigate this conflict through disclosure in this Brochure. A client’s total cost to own some Affiliated Funds will be higher than the cost of owning other, similar unaffiliated funds that are equally appropriate for a client’s account. Higher fees reduce fund performance and therefore account performance. Conflicts of Interest for Purchases of Third-Party Funds City National Rochdale has an incentive to invest client assets in products of sponsors and fund managers that share their revenue with us, over other products of sponsors or fund managers that do not share their revenue or who share less. City National Rochdale has a conflict of interest in earning more fees for itself and its affiliates. A client’s total cost to own such funds may be higher than the cost of owning other, similar funds that are equally appropriate for a client’s account that do not share their revenue with us. Higher costs reduce performance and therefore account performance. City National Rochdale seeks to mitigate this conflict through disclosure in this Brochure. Fees Incurred from Unaffiliated Fund Transfers (Surrender Charges or CDSCs) If a client transfers a previously purchased investment into a City National Rochdale account, such as a mutual fund, annuity or alternative investment, or liquidates the previously purchased investment and transfers the proceeds into a City National Rochdale account, clients may incur a fee (sometimes called a “surrender charge,” “contingent deferred sales charge” or “CDSC”) upon the sale or redemption in accordance with the investment product’s prospectus. In many cases, the CDSC is only charged if a client does not hold the security for a minimum period of time. If a client transfers a previously purchased mutual fund into an account that is subject to a CDSC, then the client will pay that charge when the mutual fund is sold, unless the client instructs otherwise. These fees are disclosed in separate disclosure documents clients will receive from the third-party mutual fund, annuity, or alternative investment. If CNR determines that any mutual fund, annuity, or alternative investment that was transferred into the account to be inconsistent with the Client’s investment objectives and Page 18 of 50  strategy, CNR will sell such holdings, and Client may be subject to a CDSC charge. Closed-End and Private Investment Fund Fees and Compensation: Clients invested in closed-end funds and private investment funds will bear a proportionate share of the fees and expenses of any fund in which their assets are invested. The fund fees and expenses are in addition to City National Rochdale’s asset-based fees reflected in the above fee schedules. These closed-end fees and expenses typically include investment advisory, administrative, transfer agent, custodial, legal, audit and other customary fees and expenses. City National Rochdale has a material conflict of interest in recommending to clients that they invest in closed-end funds that pay it and/or its affiliates fees, which are credited back based upon client agreement and/or regulatory requirements. This is because City National Rochdale has a financial incentive to recommend funds based on the fees its affiliates will earn rather than on a client’s needs. City National Rochdale seeks to mitigate this conflict through disclosure in this Brochure. The client is encouraged to read the prospectuses, SAIs or other offering documents of the funds in which the account assets are invested for a more complete explanation of these fees and expenses. Qualified Retirement Plans and IRAs: Shareholder Servicing Fees: The shareholder servicing fees are 0.25% of assets for clients who are invested in the Servicing Class, Class N shares or Class Y shares of the City National Rochdale Funds or in the City National Rochdale Interval Funds. Please see the fee Affiliated Fund Fee Table, above, for relevant rebates of these fees for qualified retirement plans and IRAs invested in the City National Rochdale Interval Funds. Transaction Fees: Set-Up/Renewal of a Note Incoming or Outgoing Payment on Note Set-Up/Close Out of Unique Asset Disbursements (includes 1099R) Insurance Policies (Holding Fee) $50.00 $7.50 $200.00 $7.50 $7.50/year Payment of Fees: Each client pays an asset-based fee in accordance with the fee schedules shown above calculated based on the daily average asset value of their account, and is charged monthly in arrears. In computing the asset value of an account, a security listed on a national securities exchange will be valued, as of the valuation date, at the closing price on the principal exchange on which it is traded. Any other security in an account will be valued in a manner determined by CNB or its agents in good faith to reflect fair market value. CNB relies on valuations furnished by vendors and/or their independent pricing services. Clients authorize CNB as custodian to deduct the asset-based fees from their custody account. The client should consider that, depending upon a number of factors, including the level of the fee charged and the amount of activity in the client’s account, the investments can cost the client more or less than purchasing the investment services separately. However, the client cannot obtain investment advisory services from City National Rochdale other than through CNB or CNS. The fees can be more or less, than fees charged by sponsors of similar programs. Clients can purchase individual securities and shares of the mutual funds directly without retaining City National Rochdale for investment management services (but subject to any applicable sales charges). The share classes of mutual funds City National Rochdale offers to clients are not available to the general public. Page 19 of 50  The fees and expenses of those mutual funds that are offered to the general public can be more or less than the fees and expenses of the share class clients use. Fees are negotiable in certain circumstances and can differ from client to client based upon a number of factors, including the amount of the assets, the client-related services to be provided to the account, the overall relationship with CNB and CNS and its affiliates and other relevant criteria. Fees also can differ as a result of the application of prior fee schedules depending upon a client’s inception date. Accounts that begin or terminate within a month are billed on a pro rata basis. Other Fees City National Rochdale’s investment management fees are exclusive of brokerage commissions, transaction fees, and other related costs that clients will pay. Clients will incur other charges imposed by brokers, and other third parties such as fees charged by managers, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees for securities transactions. Mutual funds, other pooled funds and exchange-traded funds (“ETFs”) also charge management fees, which are disclosed in a fund’s prospectus or subscription documents. Such charges, fees and commissions are exclusive of and in addition to City National Rochdale’s fee. City National Rochdale shall receive a fee for managing their Funds and City National Rochdale can receive some portion of the commissions, fees, and costs mentioned above. In many cases, the client could invest in the same mutual fund or ETF without paying a fee to City National Rochdale, however, the client would then not receive advice, review and monitoring services from City National Rochdale. City National Rochdale receives investment management fees from the Funds out of which City National Rochdale pays sub-advisers who provide day-to-day investment management services to those Funds utilizing a third-party sub-adviser. The fees that City National Rochdale receives are disclosed in each Fund’s prospectus or offering documents. Retirement Accounts When an ERISA or IRA account owns the Funds or RBC Funds, City National Rochdale does not collect fund management fees at both the fund and the account level. For the Funds that use sub-advisers, clients will receive fee credits equivalent to the net fund management fees City National Rochdale retains after paying third-party sub-advisers. Accordingly, clients will pay management fees at both the Fund level and the client managed account level. City National Rochdale will credit to ERISA or IRA accounts any 12b-1 fees it or its affiliates receive from the Funds. City National Rochdale and its affiliates receive shareholder servicing fees on the Funds, RBC Funds, and third-party funds that are held in ERISA and other tax-qualified retirement accounts and does not credit these fees to the account. Page 20 of 50  Item 6 – Performance-Based Fees and Side-By-Side Management City National Rochdale does not receive performance-based fees from the Funds. Page 21 of 50  Item 7 – Types of Clients City National Rochdale provides portfolio management services to high-net-worth individuals as well as to registered investment companies, a private fund and institutional clients, such as pension and profit-sharing plans, charitable organizations, municipalities, CNB and CNS (City National Rochdale serves as a sub- adviser to CNB and CNS). City National Rochdale generally requires a minimum of $250,000 of assets under management for a separately managed account sub-advisory relationship with CNB, but can waive this minimum in its sole and absolute discretion. If the account size falls below the minimum requirement due to market fluctuations, a client will not be required to invest additional funds to meet the minimum account size. Certain affiliated and non- affiliated sponsor programs can impose different initial or ongoing investment minimums. City National Rochdale will request that clients provide proof of authority, directed trading letters, qualified client or qualified purchaser status, accredited investor certifications, and/or other information. When providing services to clients that are subject to ERISA, we may rely on various Prohibited Transaction Exemptions (“PTEs”) available under ERISA, including PTE 84-14, which is only available to qualified professional asset managers (the “QPAM Exemption”). On March 5, 2024, the French Court of Appeal rendered a judgment of conviction (the “Conviction”) against Royal Bank of Canada Trust Company (Bahamas) Limited (“RBCTC Bahamas”), an affiliate of RBC Capital Markets LLC, and other parties regarding a charge of complicity in estate tax fraud relating to actions taken relating to a trust for which RBCTC Bahamas serves as trustee. In 2016, RBC was granted an exemption by the U.S. Department of Labor that allowed RBC and its current and future affiliates to continue to qualify for the QPAM Exemption under ERISA despite the conviction of RBCTC Bahamas in the French proceeding for a temporary one-year period from the date of conviction. In August 2025, the U.S. Department of Labor granted RBC an exemption providing longer-term relief, which is effective from August 12, 2025 through March 4, 2030. Page 22 of 50  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies City National Rochdale uses a variety of methods and strategies to make investment decisions and recommendations in connection with client Accounts. These methods generally entail an evaluation of investment opportunities using fundamental, technical, quantitative, and qualitative analyses to determine the intrinsic value of securities and other types of instruments. These methods, strategies and investments involve risk of loss to clients and clients must be prepared to bear the loss of their entire investment. Investment products are not bank deposits or obligations of or guaranteed by City National Bank or any subsidiary or affiliate and are not insured by the FDIC, they involve risk, including the possible loss of principal. City National Rochdale employs the following investment strategies. These strategies can be constructed as a separately managed account using individual securities affiliated funds, if authorized by the client, or third-party pooled investment funds. Galaxy City National Rochdale uses a proprietary modeling system to design asset allocation models specific to each client’s risk return requirements. Asset allocation decisions are unique to each client. At the beginning of each client relationship, City National Rochdale assesses the objectives of each client based (broadly) on their assets, liabilities and income goals. In this process, City National Rochdale utilizes a Monte Carlo analysis that is a modeling technique used to approximate the probability of certain outcomes by running multiple trial runs, called simulations, using random variables on several different allocation profiles. The projected return on investment for the portfolio is based on a combination of broad historic index returns, risks and correlations and current outlook. While this methodology is not perfect, a Monte Carlo analysis allows City National Rochdale to view probabilities of success with thousands of simulations. Past performance is no guarantee of future results. Equity City National Rochdale’s equity strategy focuses on a broad range of equity investment styles, including growth, core, and value, as well as portfolios designed to be “style-neutral.” City National Rochdale offers a broad range of equity investment strategies, each of which is described below. Some client accounts focus on specific ranges on the capitalization scale, from micro-cap, through small-cap, mid-cap and large- cap, to mega-cap. Other client accounts will focus on investment opportunities in more than one capitalization category or across all capitalization levels. Client accounts can be structured to achieve the desired blend of exposure to geographies, either domestic or international, and desired investment style, growth or income. U.S. Large Cap Core Equities City National Rochdale pursues capital appreciation strategies by taking long positions in quality companies with above average growth potential in highly ranked industries. U.S. Large Cap Select Core Equities City National Rochdale seeks to provide capital appreciation, with current income as a secondary objective, through investments in the equity securities of companies with large and medium capitalizations. Page 23 of 50  Equity Income City National Rochdale pursues dividend and income strategies by taking long positions in companies with dividend growth potential. Emerging Markets City National Rochdale may pursue investment strategies in Emerging Markets. City National Rochdale seeks to invest or partner with investment managers who invest in companies with a focus on locally listed large, medium, and small cap companies that are broadly inaccessible to U.S. investors. Liquidity Management Liquidity management portfolios are intended for clients who wish to preserve capital and earn prevailing market interest rates. Liquidity management portfolios are designed to maintain liquidity. Tax-Free Liquidity Management Seeks to provide a competitive, tax-free return focusing primarily on short-term instruments that exhibit low principal volatility. These investments include short-term municipal bonds and notes, as well as commercial paper. Taxable Liquidity Management Seeks to provide a competitive, taxable return focusing primarily on short-term instruments that exhibit low of principal volatility. Investments include government securities, corporate notes and bonds, as well as other short-term obligations such as commercial paper and certificates of deposit. Core Fixed Income Core fixed income portfolios are intended for clients who wish to invest in the longer term fixed income market defined as beyond 3 years. These portfolios are designed to protect principal while balancing yield against long-term performance. Tax-Free Intermediate Fixed Income Seeks to provide a high level of current income and capital preservation through investment in tax- exempt municipal fixed income securities. This strategy typically invests in maturities from 1-10 years. Tax-Free Intermediate-Long Fixed Income Seeks to capture potential inefficiencies in the intermediate part of the municipal bond yield curve (typically the 5-20 year portion of the municipal bond yield curve). Taxable Intermediate Fixed Income Seeks to provide a high level of current income and capital appreciation through investment in corporate bonds and notes, as well as debt securities issued by the federal government and its agencies. This strategy typically invests in maturities from 1-10 years. Tax-Free Short Intermediate Fixed Income Seeks to provide a return comprising a combination of both price and income attributes. Through a wide spectrum of investments in municipal bonds and notes, whose earnings are federally and/or state tax exempt. This strategy typically invests in maturities from 1-5 years. Taxable Short Intermediate Fixed Income Seeks to provide a return comprising a combination of both price and income attributes. This strategy covers a wide maturity spectrum, through investments in corporate bonds and notes, as Page 24 of 50  well as debt securities issued by the federal government and its agencies. This strategy typically invests in maturities from 1-5 years. Municipal High Income Seeks to provide a high level of current income that is not subject to federal income tax. Seeks investments in medium- and lower-quality bonds, which are bonds that are rated BBB+ or lower by Standard & Poor’s Ratings Services (“Standard & Poor’s”), are comparably rated by another nationally recognized statistical rating organization (“NRSRO”) or, if unrated, are determined by City National Rochdale to be of comparable quality. Typical investments include non- investment grade debt securities (commonly called “junk” bonds), which are rated BB+ or lower by Standard & Poor’s, comparably rated by another NRSRO or, if unrated, determined by City National Rochdale to be of comparable quality. Opportunistic Fixed Income Seeks to invest in income yielding securities, primarily focusing on high yield bonds (commonly known as “junk” bonds) issued by corporations, fixed and floating rate loans made to U.S. and foreign borrowers, domestic and foreign corporate bonds, asset backed securities such as collateralized loan obligations, structured investments, insurance and reinsurance investments and bank loans. The fund is invested in life insurance policies. Foreign investments include investments in companies that are operating principally in emerging market or frontier market countries. Stock Options City National Rochdale will use individual stock options to manage concentrated stock positions in a client portfolio. City National Rochdale can utilize a covered call option strategy as a means to manage concentrated stock positions and to potentially generate premium income for the client. Long put options can also be used to limit the potential decline of an individual stock held in a client portfolio. Hedging City National Rochdale utilizes a variety of financial instruments such as derivatives and options for risk management purposes. Alternative Investments The Adviser utilizes Alternative Investments for suitable clients. City National Rochdale classifies Alternative Investments as either Income-Based or Growth-Based strategies which include segments such as Private Credit and Private Equity. This alternative investment classification includes assets or strategies outside of traditional stocks, bonds, or cash. Alternative investments can be used to diversify portfolios, provide a unique return or hedge against risk, with the overarching goal of benefitting a client’s portfolio. Investing in Alternative Investments may involve risk such as illiquidity, valuation, regulatory, market and manager risk. Investments in Alternative Investments are subject to minimum investment sizes and other qualification requirements. City National Rochdale Government Money Market Fund The City National Rochdale Government Money Market Fund (the “Government Money Fund”) is a money market fund that seeks to preserve principal and maintain a high degree of liquidity while providing current income. In addition, the Government Money Fund seeks to maintain a $1.00 per share net asset value (“NAV”). The Government Money Fund invests at least 99.5% of its total assets in cash, U.S. Treasury securities and other government securities guaranteed or issued by an agency or instrumentality of the U.S. Government, and/or repurchase agreements that are fully collateralized by cash or government securities. In addition, the Fund invests at least 80% of its net assets (plus any borrowings for investment purposes) in U.S. Government securities and/or repurchase agreements that are fully collateralized by government Page 25 of 50  securities. Proprietary Quantitative Research techniques based on financial and economic data In addition to fundamental analysis performed on individual securities, City National Rochdale has created and utilizes proprietary, quantitatively oriented research in order to make its investment determinations. Sources of data include, but are not limited to, Bloomberg, and FactSet Research. City National Rochdale uses screening to help determine which industries/securities are the most attractive for purchase/retention and/or sale at any given point in time. These techniques are used in conjunction with the fundamental research performed by City National Rochdale. Fund Selection and Monitoring City National Rochdale recommends what it deems to be appropriate investment options, including third- party, proprietary and affiliated mutual funds and closed-end funds, which can help to meet the long-term investment objectives and needs of each client. City National Rochdale closely analyzes the performance of funds and sub-advisers. It also conducts due diligence reviews and analysis of its proprietary, third party and affiliated funds’ risk characteristics before recommending them to clients. CNR engages in ongoing due diligence and monitoring of the funds’ risk and performance for as long as they are offered on CNR’s platform. CNR’s due diligence program monitors for multiple types of risk—reputational, investment, operational, legal and regulatory, and potential conflicts of interest—in addition to fund performance. Sources of Information To help develop its strategies and recommendations, City National Rochdale uses a range of proprietary, commercial, and publicly available research systems that include both quantitative and qualitative factors. City National Rochdale’s proprietary systems contain pertinent financial information on individual securities, as well as broad domestic and international macroeconomic data. In addition, City National Rochdale uses commercially available services, financial publications and information services dealing with investment research, securities law, regulatory compliance, and taxation. City National Rochdale can also use private placement memoranda and other private placement due diligence materials. Such information can be obtained in print or via electronic media. Company-prepared materials (particularly prospectuses) and research releases prepared by others are also utilized. Despite City National Rochdale’s best efforts and sources of information, these do not guarantee that performance returns will be positive. All investing involves risk and can result in a loss. Material Risks (Including Significant or Unusual Risks) Relating to Investment Strategies and Types of Securities Investing in securities involves risk of loss that clients and other investors should be prepared to bear. The following are descriptions of various primary risks related to the investment strategies and types of securities used and recommended by City National Rochdale. The following list is not intended to be a complete enumeration of the risks associated with the investment strategies and types of securities used and recommended by City National Rochdale, and not all of the risks listed herein will apply to every client account or Fund. The specific risks associated with an investment in each Fund are included in that Fund’s prospectus, summary prospectus and statement of additional information, or offering memorandum, as applicable. Page 26 of 50  General Risks Borrowing Risk A Fund can borrow to meet repurchase requests or for investment purposes (i.e., to purchase additional portfolio securities). The Fund’s borrowings can be on a secured or unsecured basis and at fixed or variable rates of interest. The Fund’s ability to obtain leverage through borrowings is dependent upon its ability to establish and maintain an appropriate line of credit. Borrowing will also cost the Fund interest expense and other fees. The cost of borrowing can reduce the Fund’s return. Conflicts of Interest City National Rochdale and its affiliates are engaged in a variety of businesses and have interests other than that of managing Client accounts. The broad range of activities and interests of City National Rochdale and its affiliates gives rise to actual, potential and perceived conflicts of interest that could affect a Fund and its shareholders. Cybersecurity Risk Cybersecurity incidents can allow an unauthorized party to gain access to Fund assets, customer data (including private shareholder information), or proprietary information, or cause a Fund, City National Rochdale, and/or other service providers (including custodians, sub-custodians, transfer agents and financial intermediaries) to suffer data breaches, data corruption or loss of operational functionality. In an extreme case, a shareholder’s ability to exchange or redeem Fund shares can be affected. Defensive Investments During unusual economic or market conditions, or for temporary defensive or liquidity purposes, a Fund can invest up to 100% of its assets in cash or cash equivalents that would not ordinarily be consistent with the Fund’s investment goals. Emerging Market Securities Many of the risks with respect to foreign securities are more pronounced for investments in developing or emerging market countries. Emerging market countries can have government exchange controls, more volatile currency exchange rates, less market regulation, and less developed securities markets and legal systems, which tend to be less stable than those of more developed countries. Their economies also depend heavily upon international trade and can be adversely affected by protective trade barriers and economic conditions of their trading partners. Market Risk of Equity Securities By investing directly or indirectly in stocks, a Fund can expose you to a sudden decline in the share price of a particular portfolio holding or to an overall decline in the stock market. In addition, the Fund’s principal market segment can underperform other segments or the market as a whole. The value of your investment in the Fund will fluctuate daily and cyclically based on movements in the stock market and the activities of individual companies in the Fund’s portfolio. Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. Preferred stock is subject to the risk that the dividend on the stock can be changed or omitted by the issuer, and that participation in the growth of the issuer can be limited. Preferred stock typically has “preference” over common stock in the payment of distributions and the liquidation of a company’s assets, but is subordinated to bonds and other debt instruments. In addition, preferred stockholders generally do not have voting rights with respect to the issuing company. Page 27 of 50  Real Estate Investment Trusts (“REITs”) REITs’ share prices can decline because of adverse developments affecting the real estate industry, including changes in interest rates. The returns from REITs can trail returns of the overall market. Additionally, it is possible that a REIT will fail to qualify for favorable tax treatment. REITs typically incur fees that are separate from those of the Fund. Accordingly, a Fund’s investments in REITs will result in the layering of expenses such that shareholders will indirectly bear a proportionate share of the REITs’ operating expenses. Risks that Apply to Other Investments Derivatives Risk Derivatives include instruments and contracts that are based on and valued in relation to one or more underlying securities, financial benchmarks, indices, or other reference obligations or measures of value. Major types of derivatives include futures, options, swaps and forward contracts. Using derivatives can have a leveraging effect and increase fund volatility. Derivatives transactions can be highly illiquid and difficult to unwind or value, and changes in the value of a derivative held by the Fund could not correlate with the value of the underlying instrument or the Fund’s other investments. Many of the risks applicable to trading the instruments underlying derivatives are also applicable to derivatives trading. However, additional risks are associated with derivatives trading that are possibly greater than the risks associated with investing directly in the underlying instruments. These additional risks include, but are not limited to, illiquidity risk and counterparty credit risk. For derivatives that are required to be cleared by a regulated clearinghouse, other risks can arise from the Fund’s relationship with a brokerage firm through which it submits derivatives trades for clearing, including in some cases from other clearing customers of the brokerage firm. Healthcare Royalties The Adviser can invest client assets in a non-affiliated private pooled investment vehicle that concentrates its investments in healthcare royalties. Royalty investments involve the risk of loss in the case of default or insolvency of the party obligated to pay the royalty, particularly since most royalty obligations provide for recourse only to specific assets. Healthcare products are subject to extensive and rigorous regulation by state and federal authorities and by comparable foreign regulatory authorities. A failure to achieve clinical success and/or gain regulatory approval will materially and adversely affect the value of the investments. Insurance and Reinsurance Investments Risk The principal risk of an investment in insurance and reinsurance instruments is that a triggering event(s) (e.g., natural events, such as a hurricane, tornado or earthquake of a particular size/magnitude in a designated geographic area) will occur and a Fund will lose all or a significant portion of the principal it has invested in the security and the right to additional interest payments with respect to the security and an investor will lose money. If multiple triggering events occur that impact a significant portion of the portfolio of the Fund, the Fund could suffer substantial losses. There is no way to accurately predict whether a triggering event will occur and, because of this significant uncertainty, insurance and reinsurance investments carry a high degree of risk. Rail Car Leasing City National Rochdale can invest client assets in a non-affiliated private pooled investment vehicle that will focus on direct investments primarily in the acquisition of rail cars and assets Page 28 of 50  that are directly or indirectly related to rail cars (e.g., storage facilities). The investment manager of the private pooled vehicle and/or certain of its affiliates will engage in asset valuation, credit analysis, structured finance and other complex structuring issues. These investments are highly speculative, illiquid, involve leverage and substantial risk, including the risk of loss of the entire investment. Risks of Investing in Catastrophe Bonds (“Cat Bonds”) Cat Bonds (also known as event-linked bonds) carry large uncertainties and major risk exposures to adverse conditions. If a trigger event, as defined within the terms of a Cat Bond, involves losses or other metrics exceeding a specific magnitude in the geographic region and time period specified, a Fund can lose a portion or all of its accrued interest and/or principal invested in such security. Because Cat Bonds cover “catastrophic” events that, if they occur, will result in significant losses, catastrophe bonds carry a high degree of risk of loss and carry risk similar to “high yield” or “junk” bonds. The rating of a Cat Bond, if any, primarily reflects the rating agency’s calculated probability that a pre-defined trigger event will occur. Thus, lower-rated bonds have a greater likelihood of a triggering event occurring and loss to the Fund. In addition to the specified trigger events, Cat Bonds can expose the Fund to certain non- principal risks, including but not limited to issuer (credit) default, adverse regulatory or jurisdictional interpretations and adverse tax consequences. Risks of Investing in Industry Loss Warranties (“ILWs”) ILWs are exposed to catastrophic risks that can lead to binary performance of individual transactions. Events that trigger most payouts with respect to ILWs have historically been rare and as such, the probability of their occurrence can be difficult to predict. The performance of ILWs depends on determination of industry losses by a recognized third-party assessor. This dependency can cause substantial delays in either releasing the ILW collateral and premium funds to a Fund or paying it to the reinsured party, because the third-party assessor can require time to issue its findings of industry losses. Contracts for ILWs typically contain clauses that allow collateral release upon review of certain loss thresholds relative to certain time intervals. City National Rochdale will seek to gain exposure to ILW commitments structured to limit any conditional lock-up period to the extent commercially reasonable, but there can be no assurance such conditional lock-up period will coincide with the intended duration of the Fund’s investment. It is not expected that any delay will have a material impact on the Fund’s ability to make required distributions in order to qualify as a regulated investment company. ILWs in which the Fund invests can be documented as swaps. Generally, there will be no readily available market for ILWs. Risks Relating to Collateralized Loan Obligations (“CLOs”) In the case of most CLOs, the structured finance securities are issued in multiple tranches, offering investors various maturity and credit risk characteristics, often categorized as senior, mezzanine and subordinated/equity according to their degree of risk. If there are defaults or the relevant collateral otherwise underperforms, scheduled payments to senior tranches of such securities take precedence over those of mezzanine tranches, and scheduled payments to mezzanine tranches have a priority in right of payment to subordinated/equity tranches. CLOs can therefore present risks similar to those of other types of debt obligations and, in fact, such risks can be of greater significance in the case of CLOs depending upon the fund’s ranking in the capital structure. Investments in structured vehicles, including equity and junior debt tranches of CLOs, involve risks, including credit risk and market risk. Changes in interest rates and credit quality can cause significant price fluctuations. Page 29 of 50  Structured Investments Risk A Fund can invest in structured products, including, structured notes, credit-linked notes and other types of structured products. Holders of structured products bear risks of the underlying investments, index or reference obligation and are subject to counterparty risk. The Fund can have the right to receive payments only from the structured product, and generally does not have direct rights against the issuer or the entity that sold the assets to be securitized. While certain structured products enable the investor to acquire interests in a pool of securities without the brokerage and other expenses associated with directly holding the same securities, investors in structured products generally pay their share of the structured product’s administrative and other expenses. Although it is difficult to predict whether the prices of indices and securities underlying structured products will rise or fall, these prices (and, therefore, the prices of structured products) are generally influenced by the same types of political and economic events that affect issuers of securities and capital markets generally. If the issuer of a structured product uses shorter term financing to purchase longer term securities, the issuer can be forced to sell its securities at below market prices if it experiences difficulty in obtaining such financing, which can adversely affect the value of the structured products owned by the fund. Structured products generally entail risks associated with derivative instrument Private Credit Risk Private credit involves lending by non-bank institutions to businesses or individuals, offering customized, non-public debt solutions. This asset class has grown rapidly as traditional banks have scaled back lending due to regulations. Investors receive higher returns to compensate for illiquidity and credit risk. Loans are tailored to meet borrowers’ specific needs. Investments are often locked in for several years. Typically, middle-market companies with limited access to public capital markets. Private credit offers steady income, diversification, and low correlation to traditional assets but carries higher risk and illiquidity. It’s favored by institutional investors seeking enhanced yield in a low-rate environment. Credit Risk: Borrowers may default on their loans, resulting in potential principal and interest losses. Middle-market companies, common in private credit, often have less financial flexibility than large corporations. Illiquidity Risk: Private credit investments are not traded on public markets and often have lock- up periods of several years. Early redemption may not be possible, limiting an investor’s ability to access capital. Valuation Risk: Private loans are illiquid and not marked to market, making valuations subjective and reliant on assumptions. Mispricing could affect portfolio performance or asset allocation decisions. Concentration Risk: Many private credit funds have concentrated exposure to specific sectors, industries, or regions, amplifying risks during downturns. Interest Rate Risk: Rising interest rates could impact borrowers’ ability to service floating-rate debt, increasing default risk. For fixed-rate loans, the value of debt may decline in a rising rate environment. Leverage Risk: Borrowers often use leverage, which can amplify financial instability, especially during economic downturns. Some private credit funds may also use leverage, increasing the risk to investors. Page 30 of 50  Regulatory and Legal Risk: Private credit operates in a less regulated environment, increasing the likelihood of legal disputes or unforeseen regulatory changes. Changes in bankruptcy laws or tax treatment could impact recoveries or fund performance. Disclosure Notes for Investors: Investors in private credit should: • Understand the illiquid nature and long-term commitment of the investment. • Carefully evaluate the expertise and track record of the fund manager. • Diversify their portfolio to mitigate concentrated exposure. • Accept that private credit investments inherently carry higher risk. Page 31 of 50  Item 9 – Disciplinary Information On March 3, 2022, City National Rochdale (a subsidiary of CNB) and the SEC entered into a settlement regarding conduct that City National Rochdale self-reported to the SEC in September 2020. The SEC order made findings, which City National Rochdale neither admitted nor denied, and City National Rochdale consented to the entry of the order finding that City National Rochdale violated Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder (the “Order”). The SEC alleged that from 2016 through 2019, City National Rochdale did not adequately disclose that, where it was not prudent or possible to invest a client’s assets in the individual securities and bonds that comprise City National Rochdale’s internally developed model portfolios, City National Rochdale would invest the client’s assets in City National Rochdale’s proprietary mutual funds — which are designed to track the respective asset class allocations used in City National Rochdale’s model portfolios. City National Rochdale and its affiliates received fees from such investments. The SEC further alleged that from 2016 until January 2019, City National Rochdale received 12b- 1 fees from certain clients, such as those who invest with City National Rochdale through their third-party financial advisors, without adequately disclosing to such clients that a lower-cost share class was available to them. The SEC also alleged that City National Rochdale failed to implement policies and procedures reasonably designed to detect and prevent conflicts of interest. Under the terms of the Order, City National Rochdale was censured and agreed to pay a total of $30.4 million in disgorgement, prejudgment interest, and civil penalty, and to use those monies to establish a Fair Fund to repay affected clients. City National Rochdale has enhanced its disclosures regarding potential conflicts of interest and, as part of the Order, retained an independent compliance consultant to review its policies and procedures regarding the use of proprietary mutual funds. Page 32 of 50  Item 10 – Other Financial Industry Activities and Affiliations City National Bank and Royal Bank of Canada Other Business Activities City National Rochdale, LLC is a subsidiary of CNB. City National Rochdale, LLC and CNB are wholly owned subsidiaries of RBC USA Holdco Corporation, which is a wholly owned indirect subsidiary of RBC. RBC Capital Markets (“RBC CM”) refers clients to City National Rochdale for investment management services. RBC CM, Royal Bank of Canada Global Asset Management-US and CNB are wholly owned subsidiaries of RBC USA Holdco Corporation, which is a wholly owned indirect subsidiary of RBC. Other Financial Industry Activities or Affiliations CNB and its affiliates cooperatively purchase certain administrative programs and products. CNB also provides City National Rochdale with advice and assistance on general business issues unrelated to the investment advisory services provided by City National Rochdale. Except as described in this Item 10, City National Rochdale operates independently from each of RBC’s investment advisory affiliates, does not conduct joint operations with any of these affiliated investment advisers and does not provide investment advice that is formulated, in whole or in part, by such affiliated investment advisers. City National Rochdale, CNB and CNS share certain portfolio and client data in an effort to better serve their clients and provide a broader range of portfolio management services. CNB will use City National Rochdale’s portfolio managers to sub-advise portions of their client portfolios or will provide model portfolios for certain strategies to use to manage a portion of CNB’s client portfolios. City National Rochdale can occasionally recommend other services of CNB, which include banking, custody, and trust services that certain clients can require. These services can be obtained from other providers at a lower cost. In addition, CNB can recommend that clients invest in City National Rochdale’s affiliated investment companies or pooled investment vehicles. Unrelated Non-Affiliated Investment Advisers City National Rochdale contracts with unaffiliated investment advisers to provide sub-advisory investment services to the Funds. Please refer to the Funds disclosure documents for a list of the unaffiliated sub- advisers, including but not limited to the Fund prospectus and statement of additional information. Please see the offering memorandum or prospectus for more complete information regarding a Fund’s investment objectives, risks, fees and other expenses. City National Rochdale offers to its clients, subject to suitability and eligibility requirements, other third party managed private and registered funds that invest in alternative investments. These funds are managed by non-affiliated investment advisers, and include but are not limited to the following funds: Third-Party Investment Adviser Alcentra Limited Cityview Cliffwater LLC Corrum Capital Management Third-Party Private Fund Alcentra European Credit Opportunities Fund Alcentra Structured Credit Opportunities Fund II Alcentra European Strategic Credit Fund CV AG Opportunity Zone Fund, LP Page 33 of 50  Fundamental Partners ITE Management L.P. Neuberger Berman Oberland Capital Management LLC TriGuard Management LLC Two Seas Capital LP Cliffwater Corporate Lending Fund Corrum Capital Aviation Leasing II, LP Fundamental Partners IV, LP ITE Rail Fund L.P. NB Private Markets Access Fund NB Strategic Co-Investment Partners IV LP Oberland Healthcare Access Fund, LP Oberland Drug Royalties Fund II Montauk TriGuard Fund VIII, LP Montauk TriGuard Fund IX, LP Two Seas Global Fund, LP City National Rochdale clients who are invested in third-party funds will pay fund management fees (and performance fees where applicable) on third-party funds in addition to City National Rochdale’s investment advisory fees. Broker-Dealers Certain employees of City National Rochdale serve as officers, directors, and/or registered representatives of CNR Securities, LLC (“CNR Securities”) and CNS. CNR Securities and CNS are registered broker- dealers with the Financial Industry Regulatory Authority (“FINRA”) and affiliates of City National Rochdale. Each of these entities is also wholly owned by CNB and RBC. CNB accounts that are advised by City National Rochdale will be held in custody by CNB. When clients choose to use affiliated broker-dealers for custody and/or brokerage, City National Rochdale’s related entities will earn fees for the custody and brokerage services in addition to City National Rochdale’s investment advisory fees. Commission and fee schedules are available upon request. Investment Companies and Pooled Investment Vehicles City National Rochdale at times will recommend that clients invest in the Funds, as discussed in greater detail in Item 4, “Advisory Business.” City National Rochdale collects a fee from each of the Funds and there is an inherent conflict of interest in recommending these Funds because City National Rochdale has an incentive to earn more fees. City National Rochdale believes that investments in the Funds are in the best interests of the clients and considers client needs such as diversification and access to managers that would otherwise not be accessible. For the City National Rochdale Funds and RBC Funds, City National Rochdale generally seeks to mitigate this conflict of interest by rebating back to clients all or a portion of the advisory fees on their holdings of the City National Rochdale Funds. See Item 5, “Fees and Compensation” for additional disclosure of the City National Rochdale Funds fee rebates. Page 34 of 50  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics City National Rochdale has adopted a Code of Ethics (the “Code”) expressing the firm’s commitment to ethical conduct. City National Rochdale’s Code of Ethics describes the firm’s fiduciary duties and responsibilities to clients and sets forth the practice of supervising personal securities transactions of employees. Individuals associated with City National Rochdale can buy or sell securities for their personal accounts identical to or different from those recommended to clients. It is the express policy of City National Rochdale that no person employed by City National Rochdale shall place his or her own financial interest over that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients. To supervise compliance with the Code, City National Rochdale requires that employees with access to advisory recommendations or other inside information (“Access Persons”) provide securities holdings reports and quarterly transactions reports to the Compliance Department. City National Rochdale also requires all Access Persons to obtain approval from the Compliance Department prior to effecting transactions in their own accounts or accounts in which they have a beneficial interest. All individuals employed by or affiliated with City National Rochdale must sign, no less than annually, an attestation confirming their receipt and comprehension of the Code. City National Rochdale’s Code further includes the firm’s policy prohibiting the use of material non-public information. City National Rochdale requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisers. Certain employees are also subject to the ethics rules for broker-dealers, professional designation practices and other ethics rulemaking bodies. Any individual not in observance of the Code will be subject to discipline. City National Rochdale will provide a complete copy of its Code of Ethics to any client upon request. Client Transactions in Securities where Adviser has a Material Financial Interest City National Rochdale has discretionary authority over its clients’ investment accounts and initiates the transactions in such accounts. Transaction charges present conflicts of interest--the more transactions a client enters into, the more compensation City National Rochdale’s brokerage affiliates receive. Transaction fees will reduce a client’s investment performance. City National Rochdale can facilitate the purchase and sale of a security between two or more clients. This is known as an “internal cross” transaction and is only performed under client authorization. Prior to engaging in an internal cross transaction, City National Rochdale will ensure that the transaction is in the best interest of all client parties involved by ensuring the price is fair and properly disclosing all known potential conflicts. Neither City National Rochdale nor its affiliates will receive compensation for effecting internal cross transactions. City National Rochdale does not enter into transactions where client securities are purchased from or sold to brokerage customers of CNR Securities in what is known as an “agency cross” transaction. Investing in Securities Recommended to Clients City National Rochdale or a related person can, from time to time, have a portion of, or an interest in, a Page 35 of 50  security that is purchased or sold on behalf of an advisory client. City National Rochdale has adopted policies to avoid conflicts of interest when personnel of City National Rochdale or a related person of City National Rochdale owns, buys, or sells securities also owned by, or bought or sold for a client. City National Rochdale can recommend, buy or sell securities of issuers on behalf of its clients in which City National Rochdale’s Access Persons can also purchase, hold or sell securities. In order to monitor compliance with its personal trading policy, City National Rochdale has adopted a personal trading policy for all of its employees. City National Rochdale requires all Access Persons to obtain approval from the Compliance Department prior to effecting transactions in their own accounts or accounts in which they have a beneficial interest. For purposes of the policy, an employee’s “personal account” generally includes any account (a) in the name of the Access Person, his/her spouse, his/her children under the age of 21, whether or not residing in the same household, or other dependents residing in the same household, (b) for which the employee is a trustee or executor, or (c) which the employee controls and in which the employee or a member of his/her household has a direct or indirect beneficial interest. Page 36 of 50  Item 12 – Brokerage Practices Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions When CNR uses client brokerage commissions to obtain research or other products or services, CNR receives a benefit because CNR does not have to produce or pay for the research, products or services. CNR has an incentive to select or recommend a broker-dealer based on CNR’s interest in receiving the research or other products or services, rather than on the clients’ interest in receiving most favorable execution. CNR mitigates these conflicts of interest through the policies and procedures outlined below, which are designed so that CNR seeks to execute transactions in the best interests of its clients, taking into account several factors including research or other products and services. Investment Management Direct and Indirect Compensation If CNR is engaged for a separately managed account, the account may pay commissions and securities transaction fees to the third-party broker-dealers. CNR as Sub-Advisor receives Direct and Indirect Compensation in the form of hard and soft dollar commissions that are used to pay for research and other products and services obtained from broker-dealers within the safe harbor guidelines of Section 28(e) of the Securities and Exchange Act of 1934. CNR seeks to allocate its discretionary brokerage in a manner consistent with its fiduciary obligation to obtain best execution for its clients. Transactions are not always executed at the lowest available commission. CNR may select a broker-dealer that furnishes investment research services or products, or brokerage services relating to the execution of securities transactions, resulting in a client paying a higher commission in recognition of the value of research or brokerage services provided. In addition to execution quality, CNR may consider the value of various research services or products generating soft dollar benefits to the client. City National Rochdale will seek to execute transactions in the best interest of its clients, taking into account such factors as, but not limited to, the broker’s financial stability, execution capability, and quality of investment research. Brokerage services include the ability to most effectively execute orders consistent with the portfolio’s investment strategy. In exercising investment discretion for its clients, City National Rochdale will determine 1) which securities are to be bought and sold, 2) the amount of the securities to be bought and sold, and 3) the broker or dealer who will execute the transaction. Fixed income securities are generally purchased from the issuer or a primary market maker, where City National Rochdale acts as agent or as principal on a net basis without a stated commission. Fixed income securities can also be purchased in the secondary market or from underwriters at prices that include underwriting fees. Investment services provided to clients (other than an investment company) are subject to the terms and conditions of the client’s contract with City National Rochdale, which can include the client’s pre- established relationship with a broker. Brokerage Selection For equity securities, City National Rochdale’s trading desk has discretion regarding which broker to use to place equity trades. Trading operations maintains a list of brokers utilized for equity transactions that are executed. For equity trades below 1,000 shares, City National Rochdale will automatically route these trades to SIDCO for auto execution. Page 37 of 50  For fixed income securities trades, City National Rochdale can achieve economies of scale through aggregating trading positions and thus benefit from price/volume discounts, or it can negotiate on smaller issues to provide the best value to the portfolio. City National Rochdale utilizes a multi-level bid/offer process that evaluates daily offerings from a variety of brokers. Yields/prices on issues of like quality and maturity are closely scrutinized to determine executing brokers for fixed income trades. Proprietary Research and Other Brokerage Services CNR receives proprietary research and brokerage services from certain broker-dealers that execute trades for CNR’s clients. Proprietary research generally includes access to internal investment research, economic analysis, industry and company reviews, and investment performance publications that assist CNR in its investment decision-making process. This type of research does not have an identifiable value and is provided based on total trading activity of CNR for all of its clients. In 2024, the following broker-dealers provided proprietary research to CNR: Citigroup JPMorgan Evercore – ISI Stifel Nicolaus Goldman Sachs Wells Fargo Jeffries City National Rochdale will generally seek “best execution” in light of the circumstances involved in transactions. Transactions are not always executed at the lowest available commission. City National Rochdale can select a broker-dealer that furnishes investment research services or products, or brokerage services relating to the execution of securities transactions, resulting in clients paying a higher commission to such broker-dealer than that which another broker-dealer might have charged for effecting the same transaction, in recognition of the value of research or brokerage services provided. In addition to execution quality, City National Rochdale can consider the value of various research services or products, beyond execution, that a broker-dealer provides to City National Rochdale or its client. Hard and Soft Dollar Arrangements In addition to proprietary research, CNR receives third-party research, and brokerage and non-brokerage services and/or credits from certain broker-dealers that execute trades for CNR’s clients, including the Plan, under “soft dollar” agreements or arrangements. The hard and soft dollar commission arrangements are as follows: Broker-Dealer Hard Dollar Commission Per Share Soft Dollar Commission Per Share $0.0070 $0.028 Instinet $0.0112 $0.0238 SEI/SIDCO Selecting a broker-dealer in recognition of such other services or products is known as paying for those services or products with “soft dollars.” In some cases, research is provided directly by an executing broker- dealer and in other cases, research can be provided by third-party research providers, provided that the executing broker shall be solely obligated for compensation to such provider. Third-Party Research Services In 2024, CNR utilized the above noted hard and soft dollar commission arrangements to obtain third-party research services from the providers listed directly below. The research services were not provided to CNR with respect to any specific CNR client or investment product. As a result, an estimate of the value of the Page 38 of 50  research services received by CNR in connection with a specific plan is not calculable with any level of precision. CNR has the discretion to make changes to its third-party research providers as well as its hard and soft dollar commission arrangements without notice or consent to its clients. Leerink Partners LLC Merger Market Moody's Analytics Morningstar Inc MSCI MSCI ESG Research LLC Municipal Market Analytics Inc. NASDAQ International Exchange Ned Davis NYSE Market Inc NYSE Market Service Options Price Reporting Authority Oxford Economics Standard & Poor Global (S&P) Street Account (Factset) Thomson Reuters Wolfe Research Wolters Kluwer - Blue Chip Economic Indicator Barra/MSCI BCA Research Inc. Bloomberg Capital Economics Cornerstone Macro LP Credit Sights Inc (Fitch) Decision Economics Empirical Research Partners EverCore Group LLC Factset Fitch Solutions Gartner Inc ICE Data Services Interactive Data Subscription Interactive Data Subscription Interactive Data Subscription InvestorTools - CreditScope InvestorTools - PERFORM InvestorTools - SMART Research services furnished by direct research providers or third-party research providers generally can be used by City National Rochdale for its clients, as well as by CNB for any or all of its clients. City National Rochdale, CNB, and their clients share research services and products paid for in this manner. In addition, research services generally can be used in connection with accounts other than those whose commissions were used to pay for such research services. Research services include fundamental equity analytics, fundamental economic analyses, asset allocation analytics, and stock selection modeling. With respect to fixed income securities, research services include real-time alerts/analytics on ratings actions, and reviews of issuer credit and liquidity factors, among other things. Research services also include various trading and quotation services and advice from broker- dealers as to the value of securities, availability of securities, availability of buyers, and availability of sellers. The research services City National Rochdale receives can influence its judgment in allocating brokerage business between firms that provide research services and firms that do not. City National Rochdale can pay a brokerage commission in excess of what another broker-dealer might charge for effecting the same transaction. In such a case, City National Rochdale will determine in good faith that such a commission is reasonable in relation to the value of brokerage, research and other services and soft dollar relationships provided by such broker-dealer, viewed in terms of either the specific transaction or City National Rochdale’s overall responsibilities to its clients. Investment Allocations City National Rochdale’s investment personnel can recommend to, buy or sell securities of issuers on behalf of City National Rochdale’s clients and CNB accounts. Investment decisions for City National Rochdale, CNB and CNS accounts are reached independently. However, City National Rochdale personnel acting in their CNB capacity can engage in transactions for a CNB or CNS account at the same time and in the same security as a transaction for City National Rochdale clients. Page 39 of 50  With respect to equities, account allocations are assigned a random number. Allocations that individually can be completely filled with the executed shares are considered first, the allocations that can be filled only partially are considered last. Within the two groups described above, the allocations are sorted by the random number and filled with the remaining executed shares; and if an allocation cannot be filled completely, it is split amongst clients. With respect to fixed income securities, when investment personnel make investment decisions at the same time and in the same securities as investment decisions made for CNB and CNS clients, City National Rochdale’s fixed income portfolio managers can execute trades as part of concurrent authorizations to purchase or sell the same security for numerous accounts. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they will be effected only when City National Rochdale portfolio managers believe that to do so will be in the best interests of the affected accounts. When such concurrent authorizations occur, the executions vary on a case-by-case basis, but are generally allocated, including any cost or proceeds, among City National Rochdale’s clients and CNB and CNS clients, on a pro rata basis using separate accounts for each. If an allocation results in an odd lot, City National Rochdale’s procedures are designed to provide allocations that are fair and equitable to clients. In all other cases, transactions can be allocated using one of the following methodologies: first in - first placed, percentage allocation and rotation. Other subjective allocation methodologies that the portfolio manager deems to be in the client’s best interest are permissible provided that they are employed with general consistency and operate fairly. Research and Other Soft Dollar Benefits City National Rochdale receives research or other products or services other than execution from a broker- dealer and/or a third party in connection with client securities transactions. This is known as a “soft dollar” relationship. City National Rochdale will limit the use of soft dollars to services that constitute research and execution within the meaning of Section 28(e) of the Securities Exchange Act of 1934, as amended. The City National Rochdale Best Execution Committee periodically reviews and evaluates City National Rochdale’s soft dollar practices to determine in good faith whether, with respect to any research or other products or services received from a broker-dealer, the commissions used to obtain those products and services were reasonable in relation to the value of the brokerage, research or other products or services provided by the broker-dealer. The use of client commissions (or markups or markdowns) to obtain research and brokerage products and services provides a benefit to City National Rochdale that the City National Rochdale does not pay for. This creates an incentive for City National Rochdale to select or recommend a broker-dealer based on its interest in receiving those products and services. City National Rochdale at times will cause clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as paying-up), resulting in higher transaction costs for clients. Research and brokerage services obtained by the use of commissions arising from a client’s portfolio transactions are used by City National Rochdale in its other investment activities, including for the benefit of other client accounts that are directed to use other broker-dealers. These clients will receive the benefits of such services without paying for them. City National Rochdale does not seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. Page 40 of 50  Currently, research related services that City National Rochdale receives through soft dollars include: Fundamental company, security and industry analysis; Quantitative research; Economic data and forecasts; On-line research services; Portfolio risk analytical tools; Analysis of financial and market conditions; Quotation services; Valuation tools; and Statistical services. • • • • • • • • • City National Rochdale utilizes such soft dollars to pay for these research services. While it does not currently do so, City National Rochdale can in the future decide to utilize mixed use research services. If it were to do so, City National Rochdale would allocate mixed-use research services as payable in cash by City National Rochdale (to the extent not utilized by City National Rochdale as research) or through commission costs (to the extent utilized by City National Rochdale as research). In allocating brokerage commissions from mixed-use items, City National Rochdale would make a good faith determination as to the product or service’s relation to the investment decision-making process. The receipt of mixed-use services and the determination of the appropriate allocation could create a potential conflict of interest between City National Rochdale and its clients. In general, research services obtained from brokers are used to benefit City National Rochdale’s clients as a group and not solely or necessarily for the benefit of the particular client whose trades are handled by the broker providing such services. Therefore, a client can pay commissions that include payments for research services that benefit other City National Rochdale Clients. The availability of such research services can create a conflict between the interests of clients in obtaining the lowest cost execution and City National Rochdale’s interest in obtaining such services. When a client’s brokerage commissions are used to obtain research, City National Rochdale receives a benefit because it does not have to produce or pay for the research services. Brokerage for Client Referrals In selecting or recommending broker-dealers, City National Rochdale at times uses brokers that refer clients to City National Rochdale. See Directed Brokerage disclosure, below, for additional information. Directed Brokerage Clients can choose to direct City National Rochdale to execute the client’s trades with a specified broker- dealer. When a client directs City National Rochdale to use a specified broker-dealer to execute all or a portion of the client’s securities transactions, City National Rochdale treats the client direction as a decision by the client to retain, to the extent of the direction, the discretion City National Rochdale would otherwise have in selecting broker-dealers to effect transactions. Although City National Rochdale attempts to effect such transactions in a manner consistent with its policy of seeking best execution, there will be occasions where it is unable to do so, in which case City National Rochdale will continue to comply with the client’s instructions. Transactions in the same security for accounts that have directed the use of the same broker will generally be aggregated. When the directed broker-dealer is unable to execute a trade, City National Rochdale will select broker-dealers other than the directed broker-dealer to effect client securities transactions. A client who directs City National Rochdale Page 41 of 50  to use a particular broker-dealer to effect transactions should consider whether such direction can result in certain costs or disadvantages to the client. Such costs can include less favorable execution of transactions. When a client directs City National Rochdale to execute the client’s trades through an unaffiliated broker- dealer, City National Rochdale will make no attempt to negotiate commissions on behalf of the client and such clients can pay materially disparate commissions depending on their commission arrangement with the specified broker-dealer. Order Aggregation City National Rochdale often purchases or sells the same security for many clients contemporaneously and using the same executing broker. It is City National Rochdale’s practice, where possible, to aggregate client orders for the purchase or sale of the same security submitted contemporaneously (or near the same time) for execution using the same executing broker. Such aggregation can enable City National Rochdale to obtain a more favorable price for clients based upon the volume of a particular transaction. In cases where trading or investment restrictions are placed on a client’s account, City National Rochdale can be precluded from aggregating that client’s transaction with others. If the order at a particular broker is filled at several different prices through multiple trades, generally all participating accounts will receive the average price. If an aggregated order is only partially filled, City National Rochdale’s procedures are designed to provide allocations that are fair and equitable to clients. City National Rochdale will aggregate equity Client trades when such aggregation is in the best interest of all participating Clients. City National Rochdale for fixed income can also use other allocation methods, including pro rata, if it feels it would be in the best interests of the client. City National Rochdale or its related persons participate in aggregate orders (when applicable), but will not receive any preferential treatment in the price or allocation of the trade. City National Rochdale can, consistent with its applicable policies and procedures, aggregate Client trades when aggregation is expected to be in the best interest of all participating Clients. Equity allocations are generally as follows: 1. The portfolio managers create orders in the order management system, and can place the order for immediate execution or send the order as part of the sweep process described below. 2. Sweep orders: Market orders of the same security and same side are automatically aggregated, or “swept” at set times during the day. The trading desk can further aggregate multiple sweep orders or separate orders. As sweep orders are executed at set times, clients can receive better or worse order executions. 3. A small percentage of accounts are custodied separately at the direction of the client. These accounts generally direct transactions to the broker at which the account is custodied. Clients can pay higher commissions or receive worse order execution when they direct City National Rochdale to use their custodian broker to execute trades. City National Rochdale will not negotiate commissions on behalf of the client. It is the policy of City National Rochdale to review, report, and correct trade errors that occur in connection with client account transactions as soon as possible, so that clients are not disadvantaged because of an error. City National Rochdale will reimburse clients for any direct loss resulting from the correction of a Page 42 of 50  guideline breach or trade error where such is the result of an action taken by City National Rochdale. Allocation of IPOs City National Rochdale from time-to-time purchases shares in IPOs for client accounts. City National Rochdale’s policy and practice is to allocate IPO shares fairly and equitably among its clients who are able to participate in the IPO so as not to advantage any firm personnel or related account and so as not to favor or disfavor any client or group of clients over any other. Directed brokerage arrangements can limit a client’s ability to participate in IPOs. Page 43 of 50  Item 13 – Review of Accounts Frequency and Nature of Review City National Rochdale Funds The Funds are monitored on an on-going basis. The applicable Fund administrator performs daily secondary compliance checks for each of the Funds. The Funds’ Chief Compliance Officer is notified of any portfolio limitation violation. Once notified, the Compliance Department and the applicable Fund administrator will review the portfolio limitation tests against limitations specific to the relevant Fund’s investment strategy as well as restrictions and limitations set forth in the Fund’s prospectus, SAI or other offering documents. Compliance reports are reviewed by the Funds’ Chief Compliance Officer, and any exceptions are reported to the applicable Fund’s Board. Sub-Advisers City National Rochdale monitors the performance of each sub-adviser , including, but not limited to, periodic account reviews, conference calls with the sub-advisers, on- site visits and ad-hoc inquiries. Sub-advisers to the Funds include: RIMOX Federated Hermes – US High Yield Bonds Seix Investment Advisors – US High Yield Bonds & US Bank Loans Alcentra/Benefit Street Partners – European Bank Loans & CLO Debt T. Rowe Price – Emerging Market Corporate Debt All Financial Services (soon to be officially terminated) – Life Insurance Policies CNROX: CIFC – Collateralized Loan Obligations (CLO Debt & CLO Equity) Sub-advisers for client separately managed accounts include: CIFC – Collateralized Loan Obligations (CLO Debt & CLO Equity) Client Separate Account Reviews Formal client account reviews are typically conducted annually, although a client can request more or less frequent account reviews. City National Rochdale can provide periodic reports with information about performance, transactions, and asset allocations. Informal reviews are performed more frequently as can be warranted by market conditions and client needs. Each client separate account is reviewed by the portfolio manager and/or his designee on an ongoing and regular basis to determine whether securities positions should be maintained in view of current market conditions. Matters reviewed include specific securities held, asset allocation, adherence to investment guidelines and the performance of each client account. Factors Prompting an Immediate Review of Accounts Significant market events affecting the prices of one or more securities in client accounts, changes in the investment objectives or guidelines of a particular client, or specific arrangements with particular clients can trigger reviews of client accounts on an immediate basis. Content and Frequency of Regular Account Reports Each client who maintains a separate account with City National Rochdale will receive periodic Page 44 of 50  reports from the custodian where the clients’ assets are held and can receive quarterly reports from City National Rochdale. The reports will include a summary of assets, realized and unrealized capital gains and losses, and anticipated and actual income generated by the portfolio. Item 14 – Client Referrals and Other Compensation Economic Benefits Received from Non-Clients for Providing Services to Clients In exchange for commissions generated by discretionary trading activity, City National Rochdale receives research services from a variety of brokerage firms. City National Rochdale at times directs brokerage to firms who refer clients to the firm. Item 15 – Custody City National Rochdale does not take possession of client funds or securities held in separately managed accounts; nevertheless City National Rochdale has custody of client assets through the direct debiting of management fees from client custodial accounts (where clients consent to direct debiting of management fees) or sponsorship of private funds (i.e., a limited partnership, limited liability company or some other type of pooled investment vehicle). City National Rochdale does not have custody of the assets of the City National Rochdale Funds. The assets of the City National Rochdale Funds are held in custody at U.S. Bank N.A. CNB and CNS clients receive statements monthly or at a lesser frequency as directed by the client, from CNB as the qualified custodian that holds and maintains their investment assets. City National Rochdale urges its clients to carefully review such statements and compare such official custodial records to the account statements that City National Rochdale can provide its clients. City National Rochdale’s statements can vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. City National Rochdale is deemed to have custody over assets where CNB is the qualified custodian and City National Rochdale is the sub-adviser. City National Rochdale will engage a PCAOB-registered and inspected accounting firm to conduct an annual surprise examination of those assets. Item 16 – Investment Discretion City National Rochdale receives discretionary authority from the Client at the outset of an advisory relationship to select the identity, amount and timing of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. Pursuant to the terms of the standard Investment Advisory Agreement, City National Rochdale is not required to obtain specific client consent regarding securities or amounts to be bought or sold. However, City National Rochdale manages client accounts in accordance with the clients’ stated investment objectives and the investment policy statement. City National Rochdale assumes all investment duties with respect to assets held in the investment management account and has all investment powers including sole investment authority, except that City National Rochdale is not authorized to withdraw any money or securities from the account without specific authority from the client. If assets are to be withdrawn in any name other than that of the account, the client must provide written instructions and authority. Page 45 of 50  When selecting securities, determining amounts, and timing City National Rochdale observes the investment policies, limitations and restrictions of the clients it advises. Investment guidelines and restrictions must be provided to City National Rochdale in writing. For the City National Rochdale Funds, City National Rochdale’s authority to trade securities can also be limited by certain laws and regulations. For client accounts where City National Rochdale has not been granted discretion or where discretion is limited due to client restrictions, those restrictions can affect City National Rochdale’s ability to perform the stated investment strategy and therefore, investment performance can deviate from fully discretionary accounts managed in accordance with the same strategy. Non-Managed Assets At the time that assets are transferred into an account, clients may direct CNR to maintain certain securities or assets as a “Non-Managed Asset”. CNS cannot hold a Non-Managed Asset in a managed account. As a result, written direction is required from the client via a Letter of Authorization expressly noting that the asset is to be maintained in a non-managed CNS brokerage account for the client. Non-Managed Assets are not part of Program portfolios as CNR cannot exercise investment discretion over or charge a management fee on Non-Managed Assets. Please speak with your CNR Advisor if you have any questions related to Non-Managed Assets. Item 17 – Voting Client Securities City National Rochdale has adopted proxy voting policies and procedures (the “Proxy Policies”). The Proxy Policies require City National Rochdale to vote proxies received in a manner consistent with the best interests of its clients. In certain circumstances, City National Rochdale may determine that it is in the clients' best interest not to vote securities. In the client’s investment advisory agreement, clients are given the option to delegate proxy-voting discretion to City National Rochdale. City National Rochdale will only vote proxies where clients give City National Rochdale discretionary authority to vote on their behalf. City National Rochdale seeks to vote proxies in a prudent and diligent manner intended to enhance the economic value of client assets. City National Rochdale has hired a third-party proxy advisory firm (the “Proxy Advisory Firm”) to vote proxies on its behalf. In most instances, City National Rochdale votes in accordance with the Proxy Advisory Firm’s recommendation. However, if City National Rochdale believes that the recommended vote is not in the clients’ best interest it will vote against such recommendation. As part of procedures, City National Rochdale has established a Proxy Voting Oversight Committee to monitor the effectiveness of CNR’s proxy voting process, and to address potential conflicts of interest as they arise. The Proxy Voting Committee, which meets periodically as needed, includes executive, investment, compliance, legal, and operations personnel. City National Rochdale has a conflict when it or an affiliated person has a financial interest in a proxy proposal that can compromise City National Rochdale’s independence of judgment and action in voting the proxy. When City National Rochdale’s Proxy Voting Committee determines a proxy proposal raises a material conflict of interest between City National Rochdale’s interests and those of the City National Rochdale Funds or City National Rochdale’s clients, City National Rochdale will seek to resolve the conflict in accordance with its Proxy Policies. The Proxy Voting Committee will determine how to address any such material conflicts of interest, such as suggesting to clients that they engage another party to vote the proxy on their behalf or disclosing the conflict to clients and obtaining their consent before voting. For client accounts over which City National Rochdale has proxy voting authority and that hold shares of Page 46 of 50  a City National Rochdale fund, City National Rochdale has delegated authority for voting City National Rochdale fund proxies to Glass Lewis. City National Rochdale will not, under any circumstances, reassume proxy voting authority over any City National Rochdale fund shares or otherwise direct the vote of those shares. City National Rochdale will oversee Glass Lewis, and can replace Glass Lewis with a new third party should City National Rochdale find that Glass Lewis is failing to perform in manner consistent with the best interests of City National Rochdale’s clients. The Proxy Firm’s voting policies have been approved by CNR. Clients can obtain a copy of the City National Rochdale’s proxy voting policies and procedures and information about how the City National Rochdale voted a client’s proxies by contacting City National Rochdale at (212) 702-3500. Item 18 – Financial Information Registered investment advisers are required in this Item 18 to provide you with certain financial information or disclosures about City National Rochdale’s financial condition. City National Rochdale has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients. Item 19 – Requirements for State-Registered Advisers Not applicable. Page 47 of 50  Item 20 – Appendix A CNS Investment Advisory Program Fee Schedules Investment Management Annual Fees on Market Value: Assets under Management: 1.25% on the first:………………………………………………………………$1,000,000 1.00% on the next:……………………………………………………………....$4,000,000 0.75% on the next:………………………………………………………………$5,000,000 0.50% in excess of: ............................................................................................$10,000,000 Account Minimums: Minimum Annual Fee:..................................................................................................$3,000 Minimum Annual Fee for unique or highly customized mandates:.……………......$12,500 Additional Fee………………………………...…0.25% per annum on the first $10 million Conservative Growth & Income Annual Fees on Market Value: Assets under Management: 0.80% on the first:................................................................................................$1,000,000 0.65% on the next:................................................................................................$4,000,000 0.40% on the next:............................................................................................... $5,000,000 0.30% in excess of: ............................................................................................$10,000,000 Account Minimums: Minimum Annual Fee:..................................................................................................$3,000 Minimum Annual Fee for unique or highly customized mandates:………………...$10,000 Additional Fee………………………………...…0.25% per annum on the first $10 million Fixed income Annual Fees on Market Value Assets under Management: 0.50% on the first:.................................................................................................$5,000,000 0.40% on the next: ................................................................................................$5,000,000 0.30% on excess of .............................................................................................$10,000,000 Additional Fee………………………………...…0.25% per annum on the first $10 million $250,000 Multi Strategy Investment Strategy $3,000 Minimum Fee Minimum Account Size Account Minimums: Taxable or Tax- Investment Type Exempt Taxable Short Intermediate - Standard $3,000 $500,000 Tax-Exempt Intermediate – $6,000 $1,000,000 Short Standard Intermediate – Standard $6,000 $1,000,000 Taxable or Tax- Exempt Any Strategy – Customized $12,000 $2,000,000 Taxable or Tax- Exempt Page 48 of 50  Liquidity Management Taxable & Tax Exempt Strategy - Annual Fees on Market Value: Assets under Management: 0.15% on the first:...............................................................................................$10,000,000 0.10% on the next:.............................................................................................. $10,000,000 0.08% in excess of:..............................................................................................$20,000,000 Minimum Account Size: .......................................................................................$5,000,000 Minimum Annual Fee: .................................................................................................$7,500 Qualified Retirement Plan and IRA Transaction Fees: Set-Up/Renewal of a Note…………………………………………………………….$50.00 Incoming or Outgoing Payment on Note…………………………………………….....$7.50 Set-Up/Close Out of Unique Asset…………………………………………………. $200.00 Disbursements (includes 1099R)……………………………………………………….$7.50 Insurance Policies (Holding Fee)…………………………………………………… $7.50/year BUSINESS MANAGERS ONLY WITH FIXED INCOME & LIQUIDITY MANAGEMENT Tiered Fixed Income Annual Fees on Market Value: Assets Under Management (other than Fixed Income Assets): 1.25% on the first.....................................................................................................$1,000,000 1.00% on the next.....................................................................................................$4,000,000 0.75% on the next.....................................................................................................$5,000,000 0.50% in excess of................................................................................................. $10,000,000 Fixed Income Assets Under Management: 0.30% on Fixed Income Assets Minimum Annual Fee:.....................................................................................................$3,000 Liquidity Management Taxable & Tax Exempt Strategy - Annual Fees on Market Value: Minimum Account Size:...........................................................................................$5,000,000 Minimum Annual Fee:.....................................................................................................$7,500 Assets Under Management: 0.15% on the first....................................................................................................$10,000,000 0.10% on the next....................................................................................................$10,000,000 0.08% in excess of...................................................................................................$20,000,000 Qualified Retirement Plan and IRA Transaction Fees: Set-Up/Renewal of a Note $50.00 Incoming or Outgoing Payment on Note.............................................................................$7.50 Set-Up/Close Out of Unique Asset..................................................................................$200.00 Disbursements (includes 1099R).........................................................................................$7.50 Insurance Policies (Holding Fee).........................................................................................$7.50/yr. Page 49 of 50  CNS Asset Allocation Program Fee Schedules INVESTMENT MANAGEMENT Annual Fees on Market Value Assets under Management: 1.25% on the first________________________ $1,000,000 1.00% on assets over_____________________ $1,000,000 Account Minimums: Minimum Annual Fee_____________________ $500 Transaction Fees: Equities and Exchange Traded Funds_______ $3.50 Disbursements: Check__________________________________ $5.00 Wire____________________________________ $15.00 Diversified Fixed and Conservative Growth & Income Annual Fees on Market Value Assets under Management: 0.80% on the first_________________________ $1,000,000 0.65% on assets over_____________________ $1,000,000 Account Minimums: Minimum Annual Fee $500 Transaction Fees: Equities and Exchange Traded Funds_______ $3.50 Disbursements: Check__________________________________ $5.00 Wire____________________________________ $15.00 IRAs: Additional Fees: Annual Maintenance__________________ $35.00 Termination Fee______________________ $125.00 Page 50 of 50 

Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure (this “Brochure”) Item 1 – Cover Page 400 Park Avenue, 10th Floor New York, NY 10022 Telephone: Facsimile: Internet: 212-702-3500 212-702-3535 www.cnr.com October 28, 2025 This Brochure provides information about the qualifications and business practices of City National Rochdale, LLC (“City National Rochdale”, “CNR” or the “Adviser”). If you have any questions about the contents of this Brochure, please contact us by telephone at (212) 702-3500 or CNR_Compliance@cnr.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. City National Rochdale is registered as an investment adviser with the SEC. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. Additional information about City National Rochdale is available on the SEC’s website at www.adviserinfo.sec.gov. The advisory services described in this brochure are: not insured by the Federal Deposit Insurance Corporation (“FDIC”); not a deposit or other obligation of, or guaranteed by, City National Bank, a national banking association, or any of its affiliates; and subject to investment risks, including possible loss of principal amount invested.  Item 2 – Material Changes There have been no material changes made to the Brochure since the firm’s last Brochure update on April 24, 2025. The following changes were made for the purpose of clarity. • Item 1: Cover Sheet o A named officer was removed and replaced with the general reception phone number as a • point of contact. Item 9: Voting Client Securities o A named officer was removed and replaced with the general reception phone number as a point of contact.  Page 2 Item 3 -– Table of Contents Item 1 – Cover Page ..........................................................................................................................................1 Item 2 – Material Changes.................................................................................................................................2 Item 3 -– Table of Contents ...............................................................................................................................3 Item 4 – Services, Fees and Compensation .......................................................................................................4 City National Rochdale Wrap Program ........................................................................................................4 Fees and Compensation ................................................................................................................................5 Equity Trading ..............................................................................................................................................8 Fixed Income Trading ..................................................................................................................................8 Affiliated Fund Fees .....................................................................................................................................9 Shareholder Servicing Fees ........................................................................................................................10 Distribution (12b-1) Fees ...........................................................................................................................10 Affiliated Fund Fee Table ...........................................................................................................................10 Non-Managed Assets ..................................................................................................................................12 Cash Balances and the Sweep Program ......................................................................................................12 Unaffiliated Fund and Private Investment Fund Fees and Expenses .........................................................14 Other Aspects of City National Rochdale’s Investment Advisory Business ..............................................15 Item 5 – Account Requirements and Types of Clients .....................................................................................16 Item 6 – Portfolio Manager Selection and Evaluation .....................................................................................17 Item 7 – Client Information Provided to Portfolio Managers ..........................................................................17 Item 8 – Client Contact with Portfolio Managers ............................................................................................17 Item 9 – Additional Information ......................................................................................................................18 Disciplinary Information ............................................................................................................................18 Other Financial Industry Activities and Affiliations ...................................................................................18 Proprietary Research and Other Brokerage Services .................................................................................19 Hard and Soft Dollar Arrangements ...........................................................................................................19 Third-Party Research Services ...................................................................................................................19 CNR Securities ...........................................................................................................................................20 City National Bank .....................................................................................................................................20 City National Securities ..............................................................................................................................20 Affiliated Funds ..........................................................................................................................................20 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..............................21 Client Transactions in Securities where Adviser has a Material Financial Interest ....................................21 Investing in Securities Recommended to Clients .......................................................................................22 Affiliated Transferred-In Securities ............................................................................................................22 Review of Accounts ....................................................................................................................................23 Client Referrals and Other Compensation ..................................................................................................23 Voting Client Securities ..............................................................................................................................25 Class Actions ..............................................................................................................................................26 Financial Information .................................................................................................................................26 Page 3  Item 4 – Services, Fees and Compensation Introduction City National Rochdale is a wholly-owned subsidiary of City National Bank, a national banking association (“City National Bank” or “CNB”). City National Bank is a wholly-owned subsidiary of RBC USA Holdco Corporation, which is a wholly-owned indirect subsidiary of Royal Bank of Canada. City National Rochdale is registered as an investment adviser with the SEC. City National Rochdale acquires clients in a variety of ways. The majority of clients, including clients that participate in the Wrap Program, are introduced to City National Rochdale by affiliated and unaffiliated third parties, including independent brokers, financial planners, investment advisors, consultants, CPAs, attorneys, and representatives of broker-dealers (referred to as “Referring Advisors). Referring Advisors provide services directly to clients and clients pay fees for such services. Any such services are provided solely by Referring Advisors and not by, or on behalf of, City National Rochdale. Additionally, Referring Advisors are compensated for introductions to City National Rochdale. (See Item 9 in this Brochure for further information about the activities of Referring Advisors.) City National Rochdale’s investment advisory services include sponsoring a wrap fee program that bundles investment advisory services with brokerage services and custodial services for a consolidated fee (“Wrap Program”). City National Rochdale Wrap Program Services City National Rochdale’s Wrap Program offers management of client accounts (“Account(s)”) on a fully discretionary basis including all security purchase and sale decisions. Equity securities transactions are executed through the Adviser’s broker-dealer affiliate, CNR Securities LLC (“CNR Securities”), a member of the Financial Industry Regulatory Authority (“FINRA”). Clients participating in the Wrap Program are required to use CNR Securities as their broker-dealer. CNR Securities clears all of its transactions on a fully disclosed basis through Pershing LLC (“Pershing”), however separate trade commissions are not charged for securities transactions under the Wrap Program. Pershing also serves as the custodian for all client Accounts in the Wrap Program. The City National Rochdale Wrap Program is not available for accounts maintained at and custodied by City National Bank or for accounts managed outside of CNR Securities. CNR does not have custody of the assets in Custodial Accounts. CNR, however, could be deemed to have custody over client assets because clients authorize Pershing as the custodian to deduct the Wrap Program Fees from their Custodial Accounts. Clients receive statements at least quarterly from Pershing as the qualified custodian for Wrap Program Accounts. CNR urges clients to carefully review the information in these statements against any statements provided by CNR. The Wrap Program does not include additional fees that can be charged by Pershing for administrative services provided by the Custodian. Clients are responsible for any miscellaneous administrative fees that may be charged by the Custodian, Pershing, such as retirement account custodial fees, safekeeping fees, wire transfer fees, exchange fees, transfer taxes, and other such administrative fees. Additionally, clients Page 4  who are invested in a pooled investment vehicle, mutual fund, and/or any other money market account will bear the expenses of that fund separate from fees charged by City National Rochdale for the Wrap Program. In addition to actively managing client accounts, the Wrap Program helps clients set investment objectives and determine appropriate asset allocations. A variety of investment styles can be employed, with client consultation, to establish the investment style most appropriate for the client’s investment. In providing advisory services under the Wrap Program, City National Rochdale invests in a variety of asset classes including small-, mid-, and large-cap equities and fixed income securities in domestic and international markets. As with any investment program, there is no guarantee that a client’s objective will be achieved. The Wrap Program also offers the following services and reporting: a) Meetings with the Adviser’s Portfolio Managers; b) Confirmations of purchases and sales in the Account (confirmations are not sent for purchases into money market funds processed on the sweep platform); c) Monthly statements showing activity in the Account, securities held, and month-end market value; d) Quarterly evaluations of the Account, reporting cost basis as well as market values of securities owned; and e) A comprehensive year-end report and other reports or information that clients may reasonably request. Fees and Compensation Under the Wrap Program, the client pays an annual investment advisory fee, an annual program fee, and (if applicable) an annual fee that is paid to the client’s Referring Partner. These fees are paid in accordance with the fee schedules shown below calculated on the market value of the assets in the Account, including cash held in the cash sweep program, determined as of the close of business on the last business day of the previous calendar quarter. The annual investment advisory fee and annual program fee are bundled into one total management fee (the “Wrap Fee”). Investment Advisory Fee The Investment Advisory Fee covers investment management services provided by City National Rochdale to Wrap Program Accounts. Investment Advisory Fee1, 2 Account Value First $500,000 1.00% Next $500,000 1.00% Next $1,000,000 1.00% 1 The Investment Advisory Fee is based on a tiered schedule (cumulative). Therefore, the account will be charged the respective fee listed. Therefore, on the first $2 million of assets, the account will be charged 1.00%; on the next $3 million of assets, the account will be charged 0.80%; etc. 2 City National Rochdale does not pay any portion of the Investment Advisory Fee to Portfolio Managers responsible for managing Wrap Program Accounts. Page 5  Next $1,000,000 0.80% Next $2,000,000 0.80% Next $5,000,000 0.60% $10,000,000 and above 0.50% Program Fee The Program Fee covers transaction costs of and custodial services for Wrap Program Accounts. Program Fee1, 2 Account Value 0.11% $0 to $500,000 $500,000 to $1,000,000 0.10% $1,000,000 to $2,000,000 0.07% $2,000,000 to $3,000,000 0.07% $3,000,000 to $5,000,000 0.04% $5,000,000 to $10,000,000 0.03% $10,000,000 and above 0.01% 1 The Program Fee is based on a breakpoint fee schedule where the fee is determined by the aggregate assets in the Account. Therefore, if the account value is under $500,000, the Program Fee is 0.11%. If the account value is $500,000 to $1,000,000, the Program Fee is 0.10%, and so forth. 2City National Rochdale does not pay any portion of the Program Fee to Portfolio Managers responsible for managing Wrap Program Accounts. Fee Paid to Referring Partner (if applicable) The Fee paid to the Referring Partner covers certain additional services that the client and Referring Partner agree the Referring Partner will provide to the Wrap Program Account. This fee is negotiated by each client pursuant to a separate agreement between the client and the Referring Partner that does not include City National Rochdale and therefore, City National Rochdale does not have the necessary information to provide a definitive range of fees paid to Referring Partners. The annual investment advisory fee, annual program fee, and (if applicable) annual fee paid to the Referring Partner are addressed in the investment advisory agreement between City National Rochdale and the client. Under certain circumstances, the annual investment advisory fee and annual program fee can be negotiated on a case-by-case basis and can be different from, but not higher than, the above Investment Advisory Fee Schedule and Program Fee Schedule. As noted above, the fee paid by a client to a Referring Partner is negotiated by each client pursuant to a separate agreement between the client and the Referring Partner that does not include City National Rochdale. Any fees charged by a Referring Partner are separate from the fees charged by City National Page 6  Rochdale and are not considered part of the Wrap Program annual investment advisory fee or annual program fee. It is recommended that clients review the Referring Partner’s Form ADV Part 2A disclosure brochure or other comparable disclosure statement provided by Referring Partner, which should contain additional information about the Referring Partner, services provided, fees, and other important information. Clients should note that City National Rochdale performs limited due diligence with respect to Referring Partners; therefore, clients are responsible for carefully reviewing any and all information and/or material provided by the Referring Partner, and for determining the appropriateness of the relationship and value of the services being provided and reasonableness of related fees. Clients who participate in the Wrap Program will not be charged commissions on a transaction-by- transaction basis. Securities transactions are effected “net” (i.e., without transaction based commissions) and a portion of the Program Fee is considered as being in lieu of commissions. This program can cost the client more or less than if management fees and commissions were charged separately. Custody fees payable to Pershing are not separately charged to client Accounts. Clients are responsible, however, for miscellaneous administrative fees that Pershing charges (e.g., retirement account custodial fees, safekeeping fees, wire transfer fees, IRA/ERISA account fees, annual maintenance and mark-up fees, and any other administrative fees, a list of which is available upon request). Additionally, clients who are invested in any pooled investment vehicle or mutual fund will bear the expenses of that vehicle or fund. Fund expenses vary depending upon the fund selected (See “Types of Investments” below). City National Rochdale’s investment advisory programs do not pay City National Rochdale or its employees performance fees. Accordingly, City National Rochdale does not believe that these arrangements give rise to any conflict of interest or offer any incentive for any of the firm’s investment personnel, including the Portfolio Manager responsible for managing client Accounts in the Wrap Program, to favor any vehicle over any other Account. Client facing portfolio managers are paid based on the account level fees that their clients generate. They are not paid bonuses on any performance fees or wrap fee revenue. General Information Regarding “Wrap Fees” or “All-Inclusive Fees” In establishing the Wrap Program fee schedules set forth above, City National Rochdale considered a variety of factors including costs to provide investment management services, direct communication with the Portfolio Managers, detailed client reporting, trading and clearing costs for trades executed through CNR Securities, as well as custody of client assets through Pershing. Depending, however, upon the level of the Program Fee, the amount of trading in the client’s account, the value of custodial and other services in the Wrap Program, and other factors, the cost of participating in the Wrap Program can be higher than the aggregate cost of such services if they were to be separately purchased. In the Wrap Program, securities transactions will be executed through CNR Securities without a trade commission. This means that City National Rochdale at times will receive higher fees from clients in the Wrap Program whose accounts trade infrequently than from other clients whose accounts trade frequently, or than from clients who pay an investment advisory fee plus trade commissions. Similarly, CNR Securities’ fees under the Wrap Program can be higher than fees it receives under traditional commission-based arrangements. This is because CNR Securities will receive a fee regardless of the number of trades in a client’s account during the quarter. In evaluating any wrap fee arrangement, clients should Page 7  recognize that CNR does not negotiate brokerage commissions or the execution terms of trades in client accounts not executed through CNR Securities, and has not considered those commissions in the development of our Wrap Program. Some clients favor an advisory (also known as an asset-based) fee arrangement because the fee sets their brokerage cost at a predetermined level. Other clients favor a commission arrangement because they anticipate their accounts will have little trading activity. Clients who plan to follow a buy and hold strategy for the account, or do not wish to receive ongoing investment advice or management services, should consider opening a brokerage account rather than an advisory account. Please note that City National Rochdale does not offer a traditional brokerage arrangement, so clients will open such accounts elsewhere. When assessing a wrap fee program’s cost, a client should consider the amount of anticipated trading activity and factors such as commission rates. City National Rochdale makes no guarantees that the aggregate cost of a particular program is lower than other programs. Clients should evaluate whether an advisory (asset- based fee) or brokerage (transaction-based fee) arrangement is appropriate for their needs. City National Rochdale’s investment advisory programs do not pay City National Rochdale or its employees performance fees. Accordingly, City National Rochdale does not believe that these arrangements give rise to any conflict of interest or offer any incentive for any of the firm’s investment personnel, including the Portfolio Manager responsible for managing client Accounts in the Wrap Program, to favor any vehicle over any other Account. Trading Away and other Associated Costs Equity Trading City National Rochdale’s clients do not pay additional trading costs to execute equity trades when CNR Securities is the broker-dealer that executes a trade order in a Wrap Program account. Fixed Income Trading City National Rochdale’s fixed income portfolio managers trade away and adhere to CNR’s best execution policies and procedures. Clients should expect that all fixed income trades in the Wrap Program will be executed by broker-dealers other than CNR Securities and that the client will incur transactional costs for these trades in addition to any Wrap Program fees charged by CNR. Fixed income securities are primarily traded in dealer markets. These securities are directly purchased from or sold to a financial services firm acting as a dealer or principal. A dealer can apply a commission, a markup (on securities it sells), a markdown (on securities it buys) or a spread (the difference between the price it will buy or “bid” for the security and the price at which it will sell or “ask” for the security) in the net price at which transactions are executed, which is not typically disclosed to CNR. The bid and ask are prices quoted by the dealer, so the client should understand that a dealer’s bid price would be the price at which a client is selling their security, and the dealer’s ask price would be the price at which a client is buying the security. As a result, fixed income managers and their strategies could be more costly to a client than managers that primarily place commission-based client trade orders with CNR Securities for execution. CNR's fixed income portfolio managers are not compensated based on trading and do not generate any fees, transaction costs or commissions for CNR. Page 8  Affiliated Fund Fees Depending on the objectives of a particular client, City National Rochdale recommends the use of various investment funds sponsored and advised by City National Rochdale. These funds include the City National Rochdale Funds, an open-end management investment company registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”), consisting of mutual funds (the “City National Rochdale Funds”). City National Rochdale is the investment adviser for and receives a management fee from each of the City National Rochdale Funds. City National Rochdale has retained sub-advisers for the City National Rochdale Fixed Income Opportunities Fund. City National Rochdale also provides investment advisory services to the City National Rochdale Select Strategies Fund (“CNRLX”) and City National Rochdale Strategic Credit Fund (“CNROX,” and together with CNRLX, the “City National Rochdale Interval Funds”), each a Delaware statutory trust registered under the Investment Company Act as a closed-end management investment company. City National Rochdale offers its clients, who satisfy certain suitability and eligibility requirements, interests in the City National Rochdale Interval Funds. City National Rochdale has retained a sub-adviser for CNROX. City National Rochdale manages the Special Opportunities Fund Ltd., an investment vehicle that is not registered under the Investment Company Act (the “Offshore Fund”). The Offshore Fund is domiciled in the British Virgin Islands. The Offshore Fund is currently in liquidation with an expected closure date on or around March 31, 2025 and is no longer offered to City National Rochdale clients. The City National Rochdale Funds and City National Rochdale Interval Funds are collectively referred to as the “Affiliated Funds”. City National Rochdale and/or its affiliates receive fees for investment management and other services to the Affiliated Funds. All Affiliated Funds are subject to an annual audit by an independent auditor and audited financial statements are sent to investors annually. City National Rochdale will recommend the following City National Rochdale Funds Affiliated Funds in the table below for an Account if they are appropriate, unless the client requests otherwise. City National Rochdale believes the Affiliated Funds are appropriate investments because they offer a variety of investment objectives and investment strategies and provide professional investment management, investment diversification, and convenience. When City National Rochdale buys shares of Affiliated Funds for an Account, City National Rochdale earns a management fee, City National Rochdale and/or its affiliates receive shareholder servicing fees and, for the City National Rochdale Funds, City National Rochdale’s affiliates also earn distribution (12b-1) fees. Using Affiliated Funds presents City National Rochdale with a conflict of interest, because City National Rochdale could buy similar unaffiliated funds for an Account that do not pay management fees, shareholder servicing fees, distribution (12b-1) fees, or all of them, to City National Rochdale or its affiliates. Those unaffiliated funds sometimes have lower overall fees than similar Affiliated Funds. Some of the Affiliated Funds have share classes that do not charge shareholder servicing and/or distribution (12b-1) fees, but those share classes are not available to City National Rochdale Wrap Fee Program clients. Those share classes are only available to City National Rochdale clients whose accounts are maintained at CNB, advised by CNB or CNS, and sub-advised by City National Rochdale. City National Rochdale mitigates its conflict of interest by rebating all of City National Rochdale’s portion of the fund-level management fees for the Affiliated Funds and by CNR Securities rebating all of CNR Securities’ portion of the distribution (12b-1) fees for the Affiliated Funds as shown in the Affiliated Fund Page 9  Fee Table below on a quarterly basis in arrears for all client Accounts in advisory programs, including Wrap Program Accounts. CNR will provide advance notification of any changes to the Affiliated Funds management fee and distribution (12b-1) fee rebate schedule. Shareholder Servicing Fees Shareholder servicing fees compensate City National Rochdale, CNB, and City National Securities, Inc., (“CNS”) for responding to shareholder inquiries, processing shareholder purchases and redemptions; performing shareholder account maintenance; sending fund proxy statements, annual reports and other correspondence to shareholders; and providing office space, equipment, facilities and personnel to provide these services. These and other fees are described in greater detail in the Funds’ prospectuses and statements of additional information (“SAI”). City National Rochdale and/or its affiliates retain the shareholder servicing fees received from Affiliated Funds, with the exception of ERISA qualified and other tax-deferred retirement accounts invested in the City National Rochdale Interval Funds, which are rebated entirely. Distribution (12b-1) Fees Distribution (12b-1) fees compensate CNR Securities, CNR, CNS, and CNB for paying their own personnel who are involved in distribution-related activities with respect to the applicable Affiliated Funds. CNR Securities and CNS also use distribution (12b-1) fees that they receive to pay other broker-dealers who sell Affiliated Fund shares. These and other fees are described in greater detail in the Funds’ prospectuses and SAI. These fees directly benefit CNR Securities, CNR, CNS, and CNB. City National Rochdale or its related persons receive for services to the Affiliated Funds, see Item 9 – Additional Information - Other Financial Industry Activities and Affiliations. Affiliated Fund Fee Table Shareholder Servicing Fee Distribution (12b-1) Fee City National Rochdale Funds and City National Rochdale Interval Funds Fund Management Fee Shareholder Servicing Fee Rebate Distribution (12b-1) Fee Rebate Fund Management Net Fee Rebate 0.26%1 100% 0.25% N/A None N/A Government Money Market Fund – Servicing Class 0.50% 100% 0.25% N/A 0.25% 100% Municipal High Income Fund – Class N 0.50%3 100%4 0.25% N/A 0.25% 100% Fixed Income Opportunities Fund – Class N 0.40% 100% 0.25% N/A 0.25% 100% U.S. Core Equity Fund – Class N Page 10  0.50% 1 100% 0.25% 100%5 None N/A Select Strategies Fund – Class Y 1.50%2, 2 100%4 0.25% 100%5 None N/A Strategic Credit Fund – Class Y 1 City National Rochdale (the Fund’s investment adviser (Adviser)) has contractually agreed to waive its management fee for the Government Money Market Fund such that the fee charged is 0.15% through January 31, 2026. Prior to that date, the arrangement may be terminated without penalty (a) by the Fund’s Board of Trustees, or (b) by the Adviser effective no earlier than January 31, 2026, upon at least 60 days’ prior written notice. Management fees waived by the Adviser pursuant to this arrangement will not be eligible for reimbursement by the Fund to the Adviser. 4 The Management Fee Rebate percentage reflected in the table above is applied against the net fee (net of fees paid to third party sub-advisers) paid by the Fund to City National Rochdale. Management Fees paid to third party sub-advisers are not rebated by City National Rochdale. 5 The Shareholder Servicing Fee for the Select Strategies Fund and the Strategic Credit Fund is rebated only for all ERISA qualified and other tax-deferred retirement accounts. Clients who invest in the Funds will pay management fees, Rule 12b-1 fees and/or shareholder servicing fees, as applicable, to City National Rochdale and/or its affiliates, as well as other expenses of those Funds, in addition to the City National Rochdale investment advisory fees. Some of these fees are credited back to clients based upon client agreement or regulatory requirements. Certain Funds offer a fund share class that does not include a shareholder services fee. This means that you should not assume that you will be invested in the share class with the lowest possible expense ratio that the fund provider makes available to the investing public. In addition, the share class of money market funds available as part of the cash sweep option for certain types of accounts will not necessarily be the lowest cost share class available from the money market fund. As discussed more fully in Item 5, Fees and Compensation, clients who invest in the Funds will pay management fees, Rule 12b-1 fees, shareholder servicing fees, or all of these fees, to City National Rochdale or its affiliates. Those unaffiliated funds can have lower overall fees than similar Affiliated Funds. Some of the Affiliated Funds have share classes that do not charge 12b-1 fees, but those share classes are not available to City National Rochdale wrap fee program clients. They are available only to City National Rochdale clients whose accounts are maintained at CNB, advised by CNB or CNS and sub-advised by City National Rochdale. 1 The Adviser has contractually agreed to waive its management fee and/or reimburse expenses to the extent necessary to ensure that the Select Strategies Fund’s total annual operating expenses will not exceed 1.00% and the Strategic Credit Fund’s total annual operating expenses will not exceed 1.95% (after fee waivers and/or expense reimbursements, and exclusive of front-end or contingent deferred loads, taxes, interest, brokerage commissions, acquired fund fees or expenses, extraordinary expenses such as litigation expenses, and other expenses not incurred in the ordinary course of the respective Fund’s business). These arrangements will continue until July 27, 2025 for the Select Strategies Fund and until October 1, 2025 for the Strategic Credit Fund, and will automatically renew for an additional one-year period unless sooner terminated by the respective Fund or by the Fund’s Board of Trustees upon 60 days’ written notice to the Adviser or termination of the advisory agreement between the Fund and the Adviser. The Adviser may recoup fees waived and expenses reimbursed for a period of three years following the date such reimbursement or reduction was made if such recoupment does not cause current expenses to exceed the expense limit for the respective Fund in effect at the time the expenses were paid/waived or any expense limit in effect at the time of recoupment. 2 Sub-advised Fund – The Fund Management Fee reflected in the table above is the total management fee paid by the Fund. The management fee received by City National Rochdale and Affiliates is lower. If applicable per fee schedule, only the amount received by City National Rochdale is rebated to the Account. Page 11  City National Rochdale mitigates its conflict of interest by rebating all of City National Rochdale’s portion of the fund-level management fees and distribution (12b-1) fees for the Affiliated Funds, for all client Accounts in advisory programs as shown in the chart above. Certain Affiliated Funds have a share class that does not charge distribution (12b-1) fees or shareholder servicing fees, but that share class is not available to City National Rochdale wrap fee program clients. That share class is available only to certain accounts maintained at CNB that meet a minimum initial investment requirement of $1,000,000 and certain tax- deferred retirement plans held in plan level or omnibus accounts. Periodically City National Rochdale intends to add new/additional funds to the Affiliated Funds offering. At the time a client’s Account is invested in one of these additional funds, City National Rochdale will notify the client of its intent to add the fund and will deliver the fund’s prospectus or summary prospectus to the client. Failure to object will be treated as consent to the investment in the new fund. A client can terminate approval for these additional funds by notifying City National Rochdale in writing. For ERISA qualified plans, prior to investing assets in one of these additional funds, we will provide the Plan Sponsor: (1) notice of our intent to add the fund and (2) certain disclosures in writing, including the fund’s prospectus or summary prospectus. At the time of such notice, Plan Sponsor will have the opportunity to terminate approval. Failure to provide written notification of Plan Sponsor’s intent to terminate within thirty (30) days of the notice will be deemed to be approval of the investment in the new fund. Please note that City National Rochdale may remove current Affiliated Funds. City National Rochdale may do so in its sole discretion and without providing notice. Clients should be advised that City National Rochdale’s affiliated broker-dealer, CNR Securities, may receive miscellaneous fees for transactions effected in the Affiliated Funds. In addition, City National Rochdale has an incentive to invest client assets in products of sponsors and fund managers that share their revenue with City National Rochdale, over other products or sponsors or fund managers that do not share their revenue or who share less. City National Rochdale has a conflict of interest in earning more fees for itself and its affiliates. A client’s total cost to own such funds may be higher than the cost of owning similar funds that are equally appropriate for a client’s account that do not share their revenue with City National Rochdale. Higher costs reduce performance and therefore account performance. City National Rochdale or its related persons receive for services to the Funds, see Item 9 – Additional Information - Other Financial Industry Activities and Affiliations and Item 9 – Additional Information - Brokerage Practices. Non-Managed Assets At the time that assets are transferred into an account, clients can direct City National Rochdale to maintain certain securities or assets as a “Non-Managed Asset” in their managed account. City National Rochdale may accommodate this request after receiving written instructions via a CNR and CNRS Client Directive expressly noting that the position is to be maintained in the client’s managed account as a Non-Managed Asset. City National Rochdale cannot exercise investment discretion over or charge a management fee on Non-Managed Assets. Cash Balances and the Sweep Program City National Rochdale has an incentive to invest client assets in products of sponsors and fund managers that share their revenue with us, over other products of sponsors or fund managers that do not share their Page 12  revenue or who share less. City National Rochdale has a conflict of interest in earning more fees for itself and its affiliates. A client’s total cost to own such funds may be higher than the cost of owning other, similar funds that are equally appropriate for a client’s account that do not share their revenue with us. Higher costs reduce performance and therefore account performance. City National Rochdale seeks to mitigate this conflict through disclosure in this Brochure. Pershing Custodied Accounts For accounts custodied at Pershing, City National Rochdale will automatically sweep cash balances into non-affiliated money market funds available to those accounts custodied at Pershing (“Sweep Fund”). City National Rochdale receives compensation as part of a revenue sharing arrangement for City National Rochdale client assets invested in the Sweep Funds. Interest rates received on Sweep Funds are generally lower than the interest rates available if clients make deposits directly with a bank or other depository institution or invest other money market funds or cash equivalents. City National Rochdale maintains a cash sweep arrangement with Pershing that allows Wrap Program Accounts to earn interest on cash awaiting investment (“Sweep Program”). Under this arrangement, Pershing provides Wrap Program Accounts with an automated sweep to non-affiliated money market funds (“Sweep Funds”) available on BNY Pershing’s Cash Management Choice platform. The Sweep Program is offered at no additional charge or cost to the Account. Available Sweep Funds include: Federated Hermes Government Reserves Fund – P Share Class (GRFXX); Federated Hermes Government Obligations Fund – Service Share Class (GOSXX); Federated Hermes Government Obligations Fund – Capital Share Class (GOCXX); and Federated Hermes Treasury OB – Service Shares (TOSXX) based on Account eligibility. Sweep Funds may be added or removed without prior notice. How the Sweep Program Works At the end of each business day, the client’s cash balance is automatically “swept” into a Sweep Fund based on Account eligibility, unless the client instructs City National Rochdale otherwise in writing. Conflicts City National Rochdale has a conflict of interest in offering or utilizing the Sweep Funds because City National Rochdale’s affiliate CNR Securities receives compensation on City National Rochdale client assets invested in the Sweep Funds through a revenue sharing arrangement with Pershing. This compensation is typically based on client cash balances in the Sweep Program. In addition, CNR Securities receives distribution (12b-1) fees and shareholder servicing fees from client cash balances invested in the Sweep Funds, and may receive other related compensation from Pershing or the Sweep Funds. The asset based fee charged City National Rochdale CNR is charged on all account assets, including cash held in the cash sweep program. This creates an incentive for City National Rochdale to offer and utilize the Sweep Program. City National Rochdale believes that these conflicts are addressed through: (1) the client being able to obtain the prospectus or summary prospectus for each Sweep Fund, (2) online disclosure pertaining to the Sweep Funds and yields at https://www.federatedhermes.com/us/products, (3) this Brochure provided to the client annually and when material changes occur, (4) City National Rochdale monitoring Sweep Fund yields to ensure that a reasonably competitive yield is received by Wrap Program Accounts, and (5) City National Rochdale monitoring the cash allocations of Wrap Program Accounts. Page 13  Clients are advised that returns on Sweep Funds will vary and may be higher or lower than if clients invest in other comparable money market funds or cash equivalents or the interest rates available if clients make deposits directly with a bank or other depository institution outside of the Wrap Program. Clients should carefully review the Sweep Fund prospectuses or summary prospectuses and obtain current yield and additional information regarding the Sweep Program from their Portfolio Manager. Your Portfolio Manager can also provide you with a list of currently available Sweep Funds and eligibility requirements. Clients may opt out of the Sweep Program at any time by providing written notice to City National Rochdale. For additional information, please refer to BNY Pershing’s Cash Management Solutions page at: https://www.pershing.com/us/en/what-we-provide/investment-solutions/cash-management-solutions.html . Unaffiliated Fund and Private Investment Fund Fees and Expenses Clients invested in unaffiliated funds and private investment funds through this Wrap Program will bear a proportionate share of the fees and expenses of any fund in which their assets are invested. The fund fees and expenses are in addition to Wrap Program fees reflected in the above fee schedules. These fees and expenses typically include investment advisory, administrative, transfer agent, custodial, legal, audit and other customary fees and expenses charged by the funds. City National Rochdale has a material conflict of interest in recommending to clients that they invest in funds that pay it and/or its affiliates fees. This is because City National Rochdale has a financial incentive to recommend funds based on the fees that City National Rochdale and/or its affiliates will earn rather than on a client’s needs. City National Rochdale seeks to mitigate this conflict through disclosure in this Brochure. The client is encouraged to read the prospectuses or offering documents of the funds in which the account assets are invested for a more complete explanation of these fees and expenses. Fees Incurred from Unaffiliated Fund Transfers (Surrender Charges or CDSCs) If a client transfers a previously purchased investment into a City National Rochdale account, such as a mutual fund, annuity or alternative investment, or liquidates the previously purchased investment and transfers the proceeds into a City National Rochdale account, clients may incur a fee (sometimes called a “surrender charge,” “contingent deferred sales charge” or “CDSC”) upon the sale or redemption in accordance with the investment product’s prospectus. In many cases, the CDSC is only charged if a client does not hold the security for a minimum period of time. If a client transfers a previously purchased mutual fund into an account that is subject to a CDSC, then the client will pay that charge when the mutual fund is sold, unless the client instructs otherwise. These fees are disclosed in separate disclosure documents clients will receive from the third-party mutual fund, annuity, or alternative investment. If CNR determines that any mutual fund, annuity, or alternative investment that was transferred into the account to be inconsistent with the Client’s investment objectives and strategy, CNR will sell such holdings, and Client may be subject to a CDSC charge. Closed-End and Private Investment Fund Fees and Compensation: Clients invested in closed-end funds and private investment funds will bear a proportionate share of the fees and expenses of any fund in which their assets are invested. The fund fees and expenses are in addition to Wrap Program fees reflected in the above fee schedule. These closed-end fees and expenses typically include investment advisory, administrative, transfer agent, custodial, legal, audit and other customary fees and expenses. City National Rochdale has a material conflict of interest in recommending to clients that they invest in closed-end and private funds that pay it and/or its affiliates fees, which are credited back based upon client agreement and/or regulatory requirements. This is because City National Rochdale has a financial incentive to recommend funds based on the fees its affiliates will earn rather than on a client’s needs. Page 14  Other Aspects of City National Rochdale’s Investment Advisory Business City National Rochdale provides investment management services other than the Wrap Program. Portfolio managers responsible for Wrap Program Accounts are also involved in providing investment management services to accounts that are outside of the Wrap Program. Advisory programs available through City National Rochdale are described below. In managing Accounts in the Wrap Program and in providing services in connection with the advisory programs noted below, City National Rochdale seeks to customize client portfolios, based upon the individual circumstances and requirements of the client, taking into consideration such factors as the type of client, age of the client, time horizon for investments, investment goals, cash flow needs, tax concerns and sensitivity to risk. Each advisory program is described in more detail in the City National Rochdale Form ADV Part 2A, “Firm Brochure”, which can be obtained from the client’s Portfolio Manager or the SEC’s website at www.adviserinfo.sec.gov/IAPD. City National Rochdale provides investment advisory services to clients with portfolios of $1 million and above, primarily on a discretionary basis. CNR reserves the discretion to accept clients below the $1 million threshold. City National Rochdale works with each client to determine their portfolio needs and limitations and designs an asset allocation and investment objective plan to meet their goals. Thereafter, City National Rochdale Portfolio Managers implement each plan, working directly with the client and their financial advisor. A typical client relationship will also have a third-party financial advisor to assist the client through the implementation process and work with City National Rochdale on the on-going portfolio management of the client’s assets. This includes working with a client’s already existing portfolio to efficiently build out what City National Rochdale believes to be an appropriate portfolio (i.e. utilizing existing securities where appropriate), managing across multiple types of accounts (IRA, trust, personal, joint, etc.), allowing clients to place restrictions on securities (industry, sector, etc.), types of securities (options, derivatives, etc.), and investment strategies (large cap, international, alternative, etc.), and managing a client’s portfolio in seeking to meet a client’s specific distribution needs and tax goals. To the extent the client elects to invest in pooled vehicles to implement an asset allocation program, pooled vehicles cannot accommodate a client’s restrictions. Except for the portion of each client’s account that is invested in pooled vehicles, the account is managed separately from other clients of City National Rochdale (i.e., not commingled, securities are purchased for each client’s personal account). Investment Advisory Program: Intelligently personalized and customized portfolio implementation and management for clients that meet City National Rochdale’s minimum relationship requirement of $1 million or more in portfolio assets across all accounts managed. Clients pay a commission for security trades in a separately managed account. “Intelligently personalized” refers to the integration of each client’s personal preferences, goals, financial situation and behavioral factors as part of the portfolio construction process. These considerations are based on consultative discussions among the Client, Financial Advisor, Senior Investment Consultant, and/or Portfolio Manager. Sub-advisory Services: Where City National Rochdale acts as a sub-advisor, City National Rochdale is retained by an investment adviser or bank who, in turn, has entered into an investment management agreement or comparable agreement directly with the client. Under a sub-advisory arrangement, City National Rochdale will manage accounts according to the instructions of the investment adviser who has retained City National Rochdale to act in a sub-advisory capacity. In these relationships, City National Rochdale has limited contact with clients. City National Rochdale’s investment advisory programs do not pay City National Rochdale or its employees performance fees. Accordingly, City National Rochdale does not believe that these arrangements give rise to any conflict of interest or offer any incentive for any of the firm’s investment personnel, including the Portfolio Manager responsible for managing client Accounts in the Wrap Program, to favor any vehicle over Page 15  any other Account. Client facing portfolio managers are paid based on the account level fees that their clients generate. They are not paid bonuses on any performance fees or wrap fee revenue. Item 5 – Account Requirements and Types of Clients City National Rochdale offers the Wrap Program to Clients custodied through CNR Securities with Pershing, LLC. The Wrap Program is not available for accounts custodied with City National Bank. City National Rochdale generally requires a minimum of $1 million of assets under management for a separately managed account relationship but can waive this minimum in its sole and absolute discretion. If the account size falls below the minimum requirement due to market fluctuations only, a client will not be required to invest additional funds with City National Rochdale to meet the minimum account size. City National Rochdale will request that clients provide proof of authority, directed trading letters, qualified client or qualified purchaser status, or accredited investor certifications as required, and/or other information according to its sole and absolute discretion. Other clients include institutional clients, such as pensions and profit-sharing plans, charitable organizations, and a limited number of municipalities. Retirement Accounts City National Rochdale has a fiduciary duty in managing its clients’ accounts, which means that we act in your best interest in accordance with your investment objectives, financial situation and other circumstances when providing investment advice and eliminate or make full and fair disclosure of all material conflicts of interest. In addition, to the extent that City National Rochdale provides services that constitutes “investment advice” to retirement plans or individual retirement accounts subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), City National Rochdale is a “fiduciary” as defined under Section 3(21) of ERISA or the Internal Revenue Code, as applicable. City National Rochdale also acts as a fiduciary to “Retirement Investors” under Title I of ERISA or the Internal Revenue Code (as applicable), as described under Section II(a)(1) of Department of Labor Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”). A Retirement Investor is (1) a participant or beneficiary of an employee benefit plan with authority to direct the investment of assets in his or her account or to take a distribution; (2) the beneficial owner of an IRA acting on behalf of the IRA; or (3) a fiduciary of a plan as defined under Section 3(3) of ERISA (a “Plan”) or an IRA. City National Rochdale is a fiduciary under PTE 2020-02 with respect to recommendations we make for these accounts. This means that we comply with Impartial Conduct Standards (as defined in PTE 2020-02), including a best interest standard, when providing fiduciary investment advice to you as a Retirement Investor. When providing services to clients that are subject to ERISA, we may rely on various Prohibited Transaction Exemptions (“PTEs”) available under ERISA, including PTE 84-14, which is only available to qualified professional asset managers (the “QPAM Exemption”). On March 5, 2024, the French Court of Appeal rendered a judgment of conviction (the “Conviction”) against Royal Bank of Canada Trust Company (Bahamas) Limited (“RBCTC Bahamas”), an affiliate of RBC Capital Markets LLC, and other parties regarding a charge of complicity in estate tax fraud relating to actions taken relating to a trust for which RBCTC Bahamas serves as trustee. In 2016, RBC was granted an exemption by the U.S. Department of Labor that allowed RBC and its current and future affiliates to continue to qualify for the QPAM Exemption under ERISA despite the conviction of RBCTC Bahamas in the French proceeding for a temporary one-year period from the date of conviction. In August 2025, the U.S. Department of Labor granted RBC an exemption providing longer-term relief, which is effective from August 12, 2025 through March 4, 2030. Page 16  Item 6 – Portfolio Manager Selection and Evaluation All of the Portfolio Managers responsible for client Accounts that participate in the Wrap Program are City National Rochdale professionals. Portfolio managers are selected to handle Accounts based on City National Rochdale’s assessment of the client’s individual circumstances, taking into consideration such factors as the type of client, age of the client, time horizon for investments, investment goals, cash flow needs, tax concerns and sensitivity to risk. In general, City National Rochdale hires professionals internally as Portfolio Managers on client accounts. City National Rochdale generally requires that Portfolio Managers hold an MBA (or equivalent advanced degree) and/or the Chartered Financial Analyst designation (in most cases both) and have substantial industry experience. Portfolio Managers are trained in all areas of a client’s portfolio (e.g., stocks, bonds, alternatives). A critical part of the Portfolio Manager selection process is based on individual style and compatibility with the client. The performance of client portfolios is evaluated against appropriate benchmarks for their specific asset class. Additionally, adherence to client established risk parameters, personalized objectives, and tax considerations are factors in performance expectations. Securities positions are subject to constant re-evaluation and Accounts are reviewed, on at least an annual basis, triggered by any one of a number of events including, but not limited to: (1) changes in general economic or investment market conditions; (2) a change in City National Rochdale’s portfolio strategy or its outlook regarding the prospects of a particular portfolio holding or the consideration of the purchase of a new portfolio holding; (3) changes in the client’s investment objectives or financial condition; and/or (4) the deposit or withdrawal of funds from a client’s Account. Consideration will be given to replacing a Portfolio Manager if it is determined that the client is not satisfied with the performance of the Account or level of service provided by the existing Portfolio Manager. Item 7 – Client Information Provided to Portfolio Managers Portfolio Managers use information regarding each client’s risk tolerance, investment objectives, and financial condition to construct a customized investment portfolio for the client. As indicated above, in- person or telephonic conferences with clients are generally conducted at least annually. Clients are strongly encouraged to contact their Portfolio Manager directly and to notify City National Rochdale immediately if there is any change in their risk tolerances, investment objectives or financial condition. Item 8 – Client Contact with Portfolio Managers Clients are strongly encouraged to contact their Financial Advisor(s) and/or Portfolio Managers directly when needed. Portfolio Managers are available during normal business hours. City National Rochdale imposes no additional restriction or limitation on a client’s access to their Portfolio Manager. Clients are also encouraged to notify City National Rochdale immediately, either through the client relationship team, Financial Advisor(s) or by contacting their Portfolio Manager, if there is any change in their risk tolerances, investment objectives or financial condition. Clients receive regular and continuous communications concerning the activity and status of their Accounts directly from the custodian of record. Clients also receive trade confirmations from the custodian for every security transaction that occurs as well as a periodic summary Account statement showing all activity in the Account during the previous period as well as the month-end market value. Clients also receive a quarterly evaluation report from City National Rochdale that details the cost basis and current market value for each Page 17  security in the portfolio and each asset class. This quarterly report also summarizes gains, losses, and provides the time-weighted net return of the portfolio. In-person or telephonic conferences with clients are generally conducted at least annually. Clients also have the ability to view their Accounts at City National Rochdale’s website, www.cnr.com. Various other reports are also available through the website from time to time. In appropriate cases, and as directed by clients, Referring Advisors can receive copies of quarterly performance results through their access to Portfolio Managers assigned to specific client Accounts. Item 9 – Additional Information Disciplinary Information On March 3, 2022, City National Rochdale and the SEC entered into a settlement regarding conduct that City National Rochdale self-reported to the SEC in September 2020. The SEC order made findings, which City National Rochdale neither admitted nor denied, and City National Rochdale consented to the entry of the order finding that City National Rochdale violated Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder (the “Order”). The SEC alleged that from 2016 through 2019, City National Rochdale did not adequately disclose that, where it was not prudent or possible to invest a client’s assets in the individual securities and bonds that comprise City National Rochdale’s internally developed model portfolios, City National Rochdale would invest the client’s assets in City National Rochdale’s proprietary mutual funds — which are designed to track the respective asset class allocations used in City National Rochdale’s model portfolios. City National Rochdale and its affiliates received fees from such investments. The SEC further alleged that from 2016 until January 2019, City National Rochdale received 12b-1 fees from certain clients, such as those who invest with City National Rochdale through their third-party financial advisors, without adequately disclosing to such clients that a lower-cost share class was available to them. The SEC also alleged that City National Rochdale failed to implement policies and procedures reasonably designed to detect and prevent conflicts of interest. Under the terms of the Order, City National Rochdale was censured and agreed to pay a total of $30.4 million in disgorgement, prejudgment interest, and civil penalty, and to use those monies to establish a Fair Fund to repay affected clients. City National Rochdale has enhanced its disclosures regarding potential conflicts of interest and, as part of the Order, retained an independent compliance consultant to review its policies and procedures regarding the use of proprietary mutual funds. Other Financial Industry Activities and Affiliations As noted above, City National Rochdale is an SEC-registered investment adviser, an affiliate of CNS and CNR Securities, and a wholly-owned subsidiary of CNB. City National Rochdale provides investment management services to its clients, including Wrap Program Accounts. Certain officers and/or directors associated with City National Rochdale serve as officers, directors, analysts and/or Portfolio Managers of City National Rochdale and/or CNR Securities LLC, a FINRA registered broker-dealer. City National Rochdale’s relationship as an investment adviser to the City National Rochdale Funds, and the City National Rochdale Interval Funds are material to City National Rochdale’s advisory business. As described above, certain clients invest in the City National Rochdale Funds, and the City National Rochdale Interval Funds, and/or affiliated mutual funds. City National Rochdale and/or its officers, employees and directors can also be investors in these vehicles. Although there is some potential for conflicts of interest, City National Rochdale believes these are not material in light of the requirements of the Code of Ethics adopted by City National Rochdale. Page 18  Proprietary Research and Other Brokerage Services CNR receives proprietary research and brokerage services from certain broker-dealers that execute trades for CNR’s clients, including Program Accounts. Proprietary research generally includes access to internal investment research, economic analysis, industry and company reviews, and investment performance publications that assist CNR in its investment decision-making process. This type of research does not have an identifiable value and is provided based on total trading activity of CNR for all of its clients, including Program Accounts. Hard and Soft Dollar Arrangements In addition to proprietary research, CNR receives third-party research, and brokerage and non-brokerage services and/or credits from certain broker-dealers that execute trades for CNR’s clients, including Program Accounts, under hard and soft dollar commission agreements or arrangements. As a result of these agreements or arrangements, clients may pay commissions higher than those charged by other broker-dealers. The hard and soft dollar commission arrangements are as follows: CNR has soft and hard dollar commission arrangements with the following broker-dealers: Broker-Dealer Soft Dollar Commission Per Share Hard Dollar Commission Per Share Instinet $0.028 $0.0070 SEI/SIDCO $0.0238 $0.0112 In this regard, the Sub-Advisor has determined that amount of the commissions paid in relation to Program trades is reasonable in relation to the value of the brokerage and research services provided and that the Sub- Advisor’s clients as a group, including Program Accounts, benefit from the services. Third-Party Research Services In CNR’s last fiscal year, CNR utilized the above noted hard and soft dollar commission arrangements to obtain third-party research services including, but were not limited to, analyses or reports concerning issuers, industries, securities, economic trends, and portfolio strategy. The research services were not provided to CNR with respect to any specific CNR client or investment product. As a result, an estimate of the value of the research services received by CNR in connection with a specific client is not calculable with any level of precision and CNR does not attempt to allocate soft dollar benefits proportionately across its clients. When CNR utilizes client commissions to obtain research and brokerage services, CNR receives a benefit because CNR does not have to pay (or pays a reduced rate) for the research and brokerage services. As a result, CNR may have an incentive to select or recommend a broker-dealer based on CNR’s interest in receiving research and brokerage services from that broker-dealer, rather than CNR’s clients’ interest in receiving the best price or commission (most favorable execution). This presents CNR with a conflict of interest. CNR believes that its use of hard and soft dollar commission arrangements provide appropriate assistance to CNR in its investment decision-making process and benefit clients. and CNR mitigates its conflict of interest by following certain related policies and procedures. Please refer to Item 4 – Services, Fees and Compensation above, as well as other disclosure throughout this Brochure for additional information regarding the services provided by City National Rochdale, fees related to these services, potential conflicts of interest, and how these conflicts are mitigated. For additional Page 19  information regarding the research and brokerage services that CNR obtains, please refer to CNR’s Form ADV Part 2A, Firm Brochure. CNR Securities CNR Securities is a FINRA-registered broker-dealer, an affiliate of CNR, and a wholly-owned subsidiary of CNB. CNR Securities provides a variety of broker-dealer services to its clients, including but not limited to, serving as an introducing broker to Pershing, the clearing broker and custodian for Wrap Program Accounts. In addition, CNR Securities serves as a Sub-Distribution Coordinator for the Affiliated Funds. The Affiliated Funds are distributed by SEI Investments Distribution Co. (“SIDCO” or the “Distributor”), which is unaffiliated with CNR Securities. SIDCO has entered into a Distribution Coordination Agreement with the Affiliated Funds and CNR Securities pursuant to which CNR Securities acts as Sub-Distribution Coordinator for the Affiliated Funds and receives the entirety of the fees received by SIDCO pursuant to the Distribution Plan. CNR Securities then reallows those fees to broker-dealers and service providers, including CNR and other affiliates, for payments for distribution services of the type identified in the Distribution Plan, and retains any undistributed balance of fees received from the Distributor. Please refer to disclosure throughout this Brochure and in the Affiliated Funds’ prospectuses and statement of additional information regarding the services provided by CNR Securities, potential conflicts of interest, and how these conflicts are mitigated. City National Bank City National Bank is an FDIC member; the parent company of City National Rochdale, CNR Securities, and City National Securities; and a subsidiary of Royal Bank of Canada. CNB provides a wide range of financial services to its clients. Please refer to Item 4 – Services, Fees and Compensation above for additional information regarding the services provided by CNB, potential conflicts of interest, and how these conflicts are mitigated. City National Securities CNS is registered with the SEC as a broker-dealer and investment adviser, and is a member of FINRA, an affiliate of CNR, and a wholly-owned subsidiary of CNB. In addition to sponsoring two wrap fee programs which City National Rochdale serves as sub-advisor for, CNS’ primary business is providing brokerage services to its clients. Conflicts may exist due to CNS’ affiliation with CNR, CNR serving as sub-advisor to CNS wrap fee program clients, and CNS’ use of the Affiliated Funds. CNS’ efforts to mitigate these conflicts are discussed under Item 4 – Services, Fees and Compensation. Affiliated Funds City National Rochdale is the sponsor of and investment adviser to the City National Rochdale Funds and City National Rochdale Interval Funds. As discussed above, certain clients, as well as City National Rochdale and/or its employees, directors, and officers invest in the Affiliated Funds. When City National Rochdale buys shares of Affiliated Funds for an Account, City National Rochdale earns a management fee, City National Rochdale and/or its affiliates receive shareholder servicing fees and, for the City National Rochdale Funds, City National Rochdale’s affiliates also earn distribution (12b-1) fees. Using Affiliated Funds presents City National Rochdale with a conflict of interest. City National Rochdale mitigates its conflict of interest by rebating all of City National Rochdale’s portion of the fund-level management fees for the Affiliated Funds and by CNR Securities rebating all of CNR Securities’ portion of the distribution (12b-1) fees for the Affiliated Funds on a quarterly basis in arrears for all client Accounts in advisory programs, including Wrap Program Accounts. In addition, City National Rochdale believes that its Page 20  conflict is also addressed through: (1) the Affiliated Fund prospectuses, (2) this Brochure provided to the client annually and when material changes occur, and (3) to the extent that City National Rochdale or any employee, director or officer is an investor in the Affiliated Funds, each shares in any gains or losses proportionally with all other investors. investors. For additional information on the Affiliated Funds and conflict mitigation, please see Item 4 – Services, Fees and Compensation, Affiliated Fund Fees above. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics City National Rochdale has adopted a Code of Ethics (the “Code”) expressing the firm’s commitment to ethical conduct. City National Rochdale’s Code of Ethics describes the firm’s fiduciary duties and responsibilities to clients and sets forth the practice of supervising personal securities transactions of employees. Individuals associated with City National Rochdale can buy or sell securities for their personal accounts identical to or different than those recommended to clients. It is the expressed policy of City National Rochdale that no person employed by City National Rochdale shall place his or her own financial interest over that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients. To supervise compliance with the Code, City National Rochdale requires that employees with access to advisory recommendations (“Access Persons”) or other inside information provide annual securities holdings reports and quarterly transactions reports to the Compliance Department. City National Rochdale also requires all such employees receive prior approval from the Compliance Department prior to effecting transactions meeting certain criteria. All individuals employed by City National Rochdale must sign, no less than annually, an attestation confirming their receipt and comprehension of the Code. City National Rochdale requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisers. Certain employees are also subject to the ethics rules for broker-dealers, professional designation practices and other ethics rulemaking bodies. City National Rochdale’s Code further includes the firm’s policy prohibiting the use of material non-public information. Any individual not in observance of the Code is subject to discipline. City National Rochdale will provide a complete copy of its Code of Ethics to any client upon request. Client Transactions in Securities where Adviser has a Material Financial Interest City National Rochdale has discretionary authority over its clients’ Accounts and initiates the transactions in such Accounts. City National Rochdale and CNR Securities can facilitate the purchase and sale of a security between two or more clients without either City National Rochdale or CNR Securities being the seller or the buyer. This is known as an “internal cross” transaction and is only performed under client authorization. Prior to engaging in an internal cross transaction, City National Rochdale and CNR Securities will ensure that the transaction is in the best interest of all client parties involved by ensuring the price is fair and properly disclosing all known potential conflicts. Neither City National Rochdale nor its affiliates will receive compensation for effecting internal cross transactions. City National Rochdale and CNR Securities do not enter into transactions where client securities are purchased from or sold to brokerage customers of CNR Securities in what is known as an “agency cross” transaction. Page 21  Investing in Securities Recommended to Clients City National Rochdale and/or related persons can purchase, sell or hold positions in certain investments that are recommended to, or implemented for, any of its clients. If City National Rochdale holds securities for itself that it also recommends to or implements for clients, the following restrictions and disclosure procedures are maintained for the protection of clients: • City National Rochdale will recommend to or implement for its clients the purchase or sale of the same securities held, purchased or sold by City National Rochdale or any associated person only if such transaction is consistent with the objectives of the client. • The clients’ interest will be placed before City National Rochdale in such purchases and sales to assure that, on any given day, (a) the timing of the transaction will not put the client at a disadvantage, and (b) the price obtained for the client will be the same or more advantageous than that obtained for City National Rochdale or any associated person. • Employees deemed to have knowledge of client trading activities will be regarded as Access Persons and will be required to gain approval for all personal securities transactions. Affiliated Transferred-In Securities The ultimate parent company of City National Rochdale and CNR Securities is Royal Bank of Canada (“RBC”). Securities issued (1) by or for RBC and its affiliates or (2) by a company where an officer, director, or employee of CNR or one of CNR’s affiliates services on the Board of Directors or Board of Trustees (“Affiliated Securities”) create a conflict of interest for CNR and/or CNRS as the investment manager of and broker-dealer for your portfolio. Due to this conflict of interest, CNR cannot exercise investment discretion over or charge a management fee on Affiliated Securities. To retain an Affiliated Security in your portfolio and avoid a conflict of interest, we must characterize the security as a “Non-Managed Asset” in your managed account. As a result, if a position in a portfolio is a security issued by or for RBC or an RBC affiliate, or by a company where an officer, director or employee of CNR or CNR’s affiliates serves on the Board of Directors or Board of Trustees, unless you promptly provide CNR written instructions via a CNR and CNRS Client Directive at the time the assets are transferred into the account expressly noting that the position is to be maintained in your managed account as a Non-Managed Asset, CNR will liquidate the affiliated position as soon as reasonably practicable. Please be advised that CNR and CNRS cannot guarantee trade execution at a specified price. All trade executions are subject to market conditions and other circumstances. In no event will CNR and/or CNRS be responsible for any loss related to the liquidation. For Non-Managed Assets, CNR and CNRS: • will not provide any investment advice related to the security, • will not charge a management fee on the position (or will rebate/credit back to you any management fees assessed on the position and paid to CNR), • will not vote proxies for the security, • must receive written direction from you for any future transactions on the security, and • will issue a trade confirmation for any client directed trading in the Non-Managed Asset. Page 22  Review of Accounts City National Rochdale conducts an initial and annual investment review of all Wrap Program Accounts. In addition, each Wrap Program Account is reviewed by the Account’s Portfolio Manager or his or her designee on an ongoing and regular basis to determine whether securities positions should be maintained in view of current market conditions. Matters reviewed include specific securities held, adherence to investment guidelines, and the performance of each client account. Factors prompting an immediate review of Wrap Program Accounts include significant market events affecting the prices of one or more securities in clients’ Accounts, changes in the investment objectives or guidelines of a particular client, or specific arrangements with particular clients that trigger reviews of a client’s Accounts on an immediate basis. Nature and Frequency of Reports Clients receive communications concerning the activity and status of their Accounts. Clients receive trade confirmations for every buy and sell that occurs, as well as a monthly summary account statement, showing all activity in the account during the previous month as well as the month-end market value. In addition to this brokerage information, City National Rochdale provides a quarterly evaluation report that details the cost basis and current market value for each security in the portfolio and each asset class. This quarterly report also summarizes gains, losses, income and expenses, transactions and provides the time-weighted net total return of the portfolio. Clients also have the ability to view their Accounts at City National Rochdale’s website, www.cnr.com. Various other reports can be made available through the website from time to time. In appropriate cases, and as directed by clients, Referring Advisors can receive copies of and results through their access to Portfolio Managers assigned to specific client Accounts. Client Referrals and Other Compensation Referrals from Third Parties The majority of clients are introduced to City National Rochdale by affiliated and unaffiliated third parties including independent brokers, financial planners, investment advisors, consultants, CPAs, attorneys, and representatives of broker-dealers (previously referred to in this Wrap Fee Brochure as “Referring Partners). Clients referred to City National Rochdale by a Referring Partner, enter into an investment advisory agreement directly with City National Rochdale. Referring Partners are compensated for introductions to City National Rochdale. Co-Advisory Arrangements Some Referring Partners provide to clients (but are not required by City National Rochdale to do so) other services such as researching investment advisory services, assisting clients with financial planning and investment objective setting, coordinating communications between the client and the CNR portfolio manager, and monitoring performance and services to ensure that clients’ needs are being met. Clients should review with Referring Partners those additional services and their fees, which can be deducted by City National Rochdale for remittance to Referring Partners. may or may not provide these services. Any such services are provided solely by Referring Partners and not by, or on behalf of, City National Rochdale. Clients should confirm what services are being provided by Referring Partners charge a fee in addition to City National Rochdale’s fees and the fee for such services. Fees charged by Referring Partners are separate from and in addition to City National Rochdale fees. If clients elect, the fee for services provided by Referring Partners to clients can be deducted by City National Rochdale for remittance to Referring Partners. The Client is responsible for determining the extent and value of Additional Services provided, if any. Page 23  Compensation Received by Us and/or Our Affiliates Separate and apart from the Wrap Program, City National Rochdale may suggest or recommend that clients use a brokerage account at an Affiliate and/or other services for their brokerage investment activity. Similarly, City National Rochdale may suggest or recommend that clients purchase our products and/or those of our Affiliates, including City National Bank. When clients use or purchase our and/or our Affiliate’s services or products, we and/or our Affiliates will receive fees and compensation. We address the conflicts of interest presented by these affiliated transactions by maintaining certain policies and procedures reasonably designed to prevent the compensation received from affecting the nature of the advice that we provide. These policies and procedures do not eliminate such conflicts of interest. Revenue Sharing Independent Advisors are typically affiliated with large regional or national financial intermediaries which include brokerage and registered investment advisor firms. These firms generally provide, among other things, to the Independent Advisor the respective regulatory, compliance, and operational infrastructure necessary for the Independent Advisor Advisors to operate their business. City National Rochdale and its affiliates compensate certain brokerage or registered investment advisor firms for services such as, but not limited to, placing City National Rochdale’s investment management services and/or the Affiliated Funds on the firm’s preferred or recommended list, granting City National Rochdale access to the firm’s associated affiliated Independent Advisors, providing assistance in training and educating the firm’s personnel, allowing sponsorship of seminars and/or information meetings, and furnishing marketing support and certain other services. City National Rochdale also compensates these firms in order to support their ability to provide administrative support services required when the firm’s affiliated Independent Advisors conduct business with their clients through the use of City National Rochdale’s investment management services. These payments from CNR to the Independent Advisor and/or intermediaries are typically based on average net assets of City National Rochdale’s investment management business with each firm. The terms of these arrangements are tailored to the respective firms and will vary. These arrangements create a conflict of interest as they directly incentivize these firms and their affiliated Independent Advisors to promote City National Rochdale’s investment management services and Affiliated Funds. This conflict is typically mitigated by the firms not sharing such compensation directly with their affiliated Independent Advisors. The firms’ affiliated Independent Advisors do, however, benefit indirectly from these arrangements through educational opportunities, support services, and other assistance. Methods of Analysis, Investment Strategies and Risk of Loss City National Rochdale uses a variety of methods and strategies to make investment decisions and recommendations in connection with client Accounts in the Wrap Program, as well as in connection with other investment advisory programs. These methods entail an evaluation of investment opportunities using fundamental, technical, quantitative, and qualitative analyses to determine the intrinsic value of securities and other types of instruments. These methods, strategies and investments involve risk of loss to clients and clients must be prepared to bear the loss of their entire contribution/investment. City National Rochdale employs the following investment strategies that can be constructed as a separately managed account or using proprietary or non-proprietary pooled investment vehicles. Equity City National Rochdale’s equity strategy focuses on a broad range of equity investment styles, including growth, core, and value, as well as portfolios designed to be “style-neutral.” Some client accounts focus on specific ranges on the capitalization scale, from micro-cap, through small-cap, midcap and large- cap, to mega-cap. Other client accounts will focus on investment opportunities in more than one capitalization category or across all capitalization levels. Page 24  US Large Cap Core Equities City National Rochdale pursues capital appreciation strategies by taking long positions in quality companies with above average growth potential in highly ranked industries. Large Cap Select Core Equities City National Rochdale seeks to provide capital appreciation, with current income as a secondary objective, through investments in the equity securities of companies with large and middle capitalizations. Equity Income City National Rochdale pursues dividend and income strategies by taking long positions in companies with dividend growth potential. Emerging Markets City National Rochdale may pursue investment strategies in Emerging Markets. Municipal High Income City National Rochdale pursues an investment strategy that seeks to provide a level of current income that is not subject to federal income tax. Opportunistic Fixed Income Seeks to invest in income yielding securities, primarily focusing on high yield bonds (commonly known as “junk” bonds) issued by corporations, fixed and floating rate loans made to U.S. and foreign borrowers, domestic and foreign corporate bonds, asset backed securities such as collateralized loan obligations, structured investments, insurance and reinsurance investments and bank loans. The fund is invested in life insurance policies. Foreign investments include investments in companies that are operating principally in emerging market or frontier market countries. Stock Options City National Rochdale will use individual stock options to manage concentrated stock positions in a client portfolio. City National Rochdale can utilize a covered call option strategy as a means to manage concentrated stock positions and to potentially generate premium income for the client. Long put options can also be used to limit the potential decline of an individual stock held in a client portfolio. Hedging The Adviser utilizes a variety of financial instruments such as derivatives and options for risk management purposes. Alternative Investments The Adviser utilizes Alternative Investments for suitable clients. City National Rochdale classifies Alternative Investments as either Income-Based or Growth-Based strategies which include segments such as Private Credit and Private Equity. This alternative investment classification includes assets or strategies outside of traditional stocks, bonds, or cash. Alternative investments can be used to diversify portfolios, provide a unique return or hedge against risk, with the overarching goal of benefitting a client’s portfolio. Investing in Alternative Investments may involve risk such as illiquidity, valuation, regulatory, market and manager risk. Investments in Alternative Investments are subject to minimum investment sizes and other qualification requirements. Voting Client Securities City National Rochdale has adopted proxy voting policies and procedures. These policies and procedures require City National Rochdale to vote proxies received in a manner consistent with its fiduciary duties. In certain circumstances, City National Rochdale may determine that it is in the clients' best interest not to vote securities. Page 25  In the client’s investment advisory agreement, clients are given the option to delegate proxy voting to City National Rochdale. City National Rochdale will only vote proxies where clients give City National Rochdale discretionary authority to vote on their behalf. City National Rochdale seeks to vote proxies in a prudent and diligent manner intended to enhance the economic value of client assets. City National Rochdale has hired a third-party proxy advisory firm (the “Proxy Advisory Firm”) to vote proxies on behalf of its clients. In most instances, City National Rochdale votes in accordance with the Proxy Advisory Firm’s recommendation. However, if City National Rochdale believes that the recommended vote is not in the clients’ best interest it will vote against such recommendation. As part of its procedures, CNR has established a Proxy Voting Oversight Committee to monitor the effectiveness of CNR’s proxy voting process and to address potential conflicts of interest as they arise. City National Rochdale has a conflict when it or an affiliated person has a financial interest in a proxy proposal that may compromise City National Rochdale’s independence of judgment and action in voting the proxy. When City National Rochdale’s Proxy Voting Committee determines a proxy proposal raises a material conflict of interest between City National Rochdale’s interests and those of City National Rochdale Funds or City National Rochdale’s clients, City National Rochdale will seek to resolve the conflict in accordance with its adopted procedures. The Proxy Voting Committee will determine how to address any such material conflicts of interest, such as suggesting to clients that they engage another party to vote the proxy on their behalf or disclosing the conflict to clients and/or obtaining their consent before voting. For client accounts over which City National Rochdale has proxy voting authority and that hold shares of a City National Rochdale Fund, City National Rochdale has delegated authority for voting City National Rochdale Fund proxies to the proxy firm Glass Lewis. City National Rochdale will not, under any circumstances, reassume proxy voting authority over any City National Rochdale Fund shares or otherwise direct the vote of those shares. City National Rochdale will oversee Glass Lewis, and can replace Glass Lewis with a new third party should City National Rochdale find that Glass Lewis is failing to perform in manner consistent with the best interests of City National Rochdale’s clients. The Proxy Firm’s voting policies have been approved by CNR. Clients can obtain a copy of City National Rochdale’s proxy voting policies and procedures and information about how City National Rochdale voted a client’s proxies by contacting City National Rochdale at (212) 702-3500. Class Actions From time-to-time, City National Rochdale receives notices with respect to securities held or previously held in client portfolios that are subject to legal proceedings, including class actions or bankruptcies. Usually, client custodians also receive these notices and therefore generally City National Rochdale does not forward these notices to its clients or their custodians. In addition, City National Rochdale does not take legal action on behalf of or provide legal advice to clients. Financial Information CNR is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to clients. Page 26