Overview

Headquarters
Chicago, IL
Total Firm Assets
$1.1 billion
Average High-Net-Worth Client Portfolio Size
$1.0 million

Fee Structure

Primary Fee Schedule (COHEN CAPITAL FORM ADV PART 2A BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 2.00%

Minimum Annual Fee: $10,000

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

High-Net-Worth Share of Firm Assets
89.05%
Number of High-Net-Worth Clients
980
Total Client Accounts
1,478
Discretionary Accounts
1,424
Non-Discretionary Accounts
54

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection

Regulatory Filings

SEC CRD Number
339112

Primary Brochure: COHEN CAPITAL FORM ADV PART 2A BROCHURE (2026-05-04)

View Document Text
Cohen Capital Advisors, LLC dba Cohen Capital Form ADV Part 2A – Disclosure Brochure May 4, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Cohen Capital Advisors, LLC dba Cohen Capital (“Cohen Capital” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (312) 477-3155. Cohen Capital is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Cohen Capital to assist you in determining whether to retain the Advisor. Additional information about Cohen Capital and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 339112. Cohen Capital Advisors, LLC dba Cohen Capital 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Cohen Capital. Cohen Capital believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Cohen Capital encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes Cohen Capital is a newly formed registered investment advisor. Since the initial filing of Form ADV, the following material changes have been made to the Disclosure Brochure: Item 4 – Removed disclosure regarding recommendations made to retirement planning clients. Item 4 – Updated the firm’s assets under management (AUM). Item 8 – Added risks related to the cybersecurity. Item 10 – Removed disclosure related to insurance affiliations. • • • • Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 339112. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (312) 477-3155. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 2 Item 3 – Table of Contents Item 4 – Advisory Services .............................................................................................................................................. 4 Item 5 – Fees and Compensation .................................................................................................................................... 5 Item 6 – Performance-Based Fees and Side-By-Side Management .............................................................................. 7 Item 7 – Types of Clients .................................................................................................................................................. 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................... 8 Item 9 – Disciplinary Information................................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ..................................................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................ 10 Item 12 – Brokerage Practices ....................................................................................................................................... 11 Item 13 – Review of Accounts ....................................................................................................................................... 12 Item 14 – Client Referrals and Other Compensation .................................................................................................... 12 Item 15 – Custody ........................................................................................................................................................... 13 Item 16 – Investment Discretion .................................................................................................................................... 13 Item 17 – Voting Client Securities ................................................................................................................................. 13 Item 18 – Financial Information ..................................................................................................................................... 13 Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 3 Item 4 – Advisory Services A. Firm Information Cohen Capital Advisors, LLC dba Cohen Capital (“Cohen Capital” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Illinois. Cohen Capital was founded in October 2025 and commenced operations in January 2026. Cohen Capital is owned and operated by Benjamin Cohen, CFP® (Principal). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Cohen Capital. B. Advisory Services Offered Cohen Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Cohen Capital's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Cohen Capital provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Cohen Capital works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Cohen Capital will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, options, and/or structured notes to meet the needs of its Clients. The Advisor may also utilize third party managers and alternative investments, as appropriate to meet the needs of the Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Cohen Capital’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Cohen Capital will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Cohen Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Cohen Capital may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Cohen Capital may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Cohen Capital may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Cohen Capital accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services Cohen Capital will typically provide a variety of financial planning and consulting services to Clients as part of a Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 4 wealth management engagement. The Advisor may offer financial planning as a separate service, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Cohen Capital may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. C. Client Account Management Prior to engaging Cohen Capital to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Cohen Capital, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Cohen Capital will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Cohen Capital will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Cohen Capital will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Cohen Capital includes securities transaction fees and custody fees as part of its wealth management fee. This single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its wealth management services for its Clients. The Advisor sponsors the Cohen Capital Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own securities transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management Cohen Capital is a newly established advisor. As of March 23, 2026, Cohen Capital has a total of $1,100,714,851 assets under management, of which $951,367,645 are managed on a discretionary basis and $149,347,206 are managed on a non-discretionary basis. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 5 A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior quarter. Wealth management fees range from 0.75% to 2.00% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The Advisor has a minimum annual fee of $10,000. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Cohen Capital will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Financial Planning Services Cohen Capital offers financial planning services as part of a wealth management engagement and fee. In certain circumstances, a Client may engage the Advisor separately for a fixed negotiated planning fee. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total costs will be provided to the Client prior to engaging for these services. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the start of each calendar quarter. The amount due is calculated by applying the quarterly rate (annual rate based on the number of days in the quarterly period) to the total assets under management with Cohen Capital at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Cohen Capital to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. Cohen Capital includes securities transaction fees and custody fees as part of its overall wealth management fee through the Cohen Capital Wrap Fee Program. Securities transaction fees for Client- directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure. The Client is responsible for all wire request fees and other costs which may be charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Cohen Capital are separate and distinct from these custody and execution fees. In addition, all fees paid to Cohen Capital for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Cohen Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 6 Capital, but would not receive the services provided by Cohen Capital which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Cohen Capital to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Cohen Capital is compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Cohen Capital is partially compensated for its financial planning services in advance of the engagement. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will promptly refund any unearned, prepaid planning fees. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Cohen Capital does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products sold to Clients. Insurance commissions earned by Advisory Persons are separate and in addition to our advisory fees. This practice presents a conflict of interest as the Advisory Person has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on a Client’s needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Item 6 – Performance-Based Fees and Side-By-Side Management Cohen Capital does not charge performance-based fees for its investment advisory services. The fees charged by Cohen Capital are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Cohen Capital does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Cohen Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses. Cohen Capital generally does not impose a minimum relationship size, but does have a minimum annual fee of $10,000, which may be reduced at the sole discretion of the Advisor. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Cohen Capital primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Cohen Capital are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Cohen Capital will be able to accurately predict such a reoccurrence. As noted above, Cohen Capital generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Cohen Capital will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Cohen Capital may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Cohen Capital will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 8 Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Cybersecurity Risks The computer systems, networks, and devices used by Cohen Capital and service providers to us employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 9 to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Cohen Capital or its management persons. Cohen Capital values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 339112. Item 10 – Other Financial Industry Activities and Affiliations Cohen Capital does not have any activities or affiliations to report under this Item. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Cohen Capital has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Cohen Capital (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Cohen Capital and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Cohen Capital’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (312) 477- 3155. B. Personal Trading with Material Interest Cohen Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Cohen Capital does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Cohen Capital does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Cohen Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Cohen Capital requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 10 D. Personal Trading at Same Time as Client While Cohen Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Cohen Capital does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Cohen Capital to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Cohen Capital does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Cohen Capital does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Cohen Capital. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Cohen Capital may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Cohen Capital will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”). Fidelity is FINRA-registered broker-dealer and member SIPC and serves as the Clients’ “qualified custodian. Fidelity will serve as the Client’s “qualified custodian.” Cohen Capital maintains an institutional relationship with Fidelity whereby the Advisor receives certain economic benefits. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Cohen Capital does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - Cohen Capital does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Cohen Capital will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Cohen Capital will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 11 B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Cohen Capital will execute its transactions through the Custodian as authorized by the Client. Cohen Capital may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Cohen Capital and periodically by the Chief Compliance Officer of Cohen Capital. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Cohen Capital if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Cohen Capital Cohen Capital may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Cohen Capital may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform As noted in item 12, Cohen Capital has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders wealth management services to Clients that maintain assets at Fidelity The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 12 Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Cohen Capital does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Cohen Capital to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Cohen Capital to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Cohen Capital generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Cohen Capital. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Cohen Capital will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Cohen Capital does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. Should the Client direct proxy statements to the Advisor, the Advisor is not authorized or obligated to act on such voting matters. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting Item 18 – Financial Information Neither Cohen Capital, nor its management, have any adverse financial situations that would reasonably impair the ability of Cohen Capital to meet all obligations to its Clients. Neither Cohen Capital, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Cohen Capital is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 13

Additional Brochure: COHEN CAPITAL FORM ADV WRAP FEE BROCHURE (2026-05-04)

View Document Text
Cohen Capital Advisors, LLC dba Cohen Capital Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”) May 4, 2026 This Form ADV2A – Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices for Cohen Capital Advisors, LLC dba Cohen Capital (“Cohen Capital” or the “Advisor”) services when offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the Cohen Capital Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the complete Cohen Capital Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure or the Cohen Capital Disclosure Brochure, please contact the Advisor at (312) 477-3155. Cohen Capital is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Wrap Fee Program Brochure provides information about Cohen Capital to assist you in determining whether to retain the Advisor. Additional information about Cohen Capital and its Advisory Persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD# 339112. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 14 Item 2 – Material Changes Form ADV2A – Appendix 1 (“Wrap Fee Program Brochure”) provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program offered by the Advisor. Material Changes Cohen Capital is a newly formed registered investment advisor. Since the initial filing of Form ADV, there have not been any material changes to the Wrap Fee Program Brochure. Future Changes From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete Cohen Capital Disclosure Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Cohen Capital. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 339112. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (312) 477-3155. Item 3 – Table of Contents Item 2 – Material Changes .................................................................................................................................... 14 Item 3 – Table of Contents .................................................................................................................................... 14 Item 4 – Services Fees and Compensation ......................................................................................................... 15 Item 5 – Account Requirements and Types of Clients ...................................................................................... 17 Item 6 – Portfolio Manager Selection and Evaluation ........................................................................................ 17 Item 7 – Client Information Provided to Portfolio Managers ............................................................................. 19 Item 8 – Client Contact with Portfolio Managers ................................................................................................ 19 Item 9 – Additional Information ............................................................................................................................ 19 Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 15 Item 4 – Services Fees and Compensation A. Services Cohen Capital Advisors, LLC dba Cohen Capital provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the Cohen Capital Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting Cohen Capital as your investment advisor. As part of the wealth management fees noted in Item 5 of the Disclosure Brochure, Cohen Capital includes security transaction fees and custody fees as part of its overall wealth management fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The Advisor’s recommended Custodian typically does not charge securities transaction fees for exchange-traded fund (“ETF”) and equity trades in Client accounts, but may charge for mutual funds and other types of investments. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of securities transaction fees, custody fees and the Advisor’s fee into a single “bundled” wealth management fee. This Wrap Fee Program Brochure references back to the Cohen Capital Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on Cohen Capital’s investment philosophy and related services. B. Program Costs Advisory services provided by Cohen Capital are offered in a wrap fee structure whereby securities transaction fees and custody fees are included in the overall wealth management fee paid to Cohen Capital. As the level of activity in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where these costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to each Client; however, the Client is not charged more if there is higher trading activity. A Wrap Fee structure presents a conflict of interest as the Advisor may be incentivized to limit the number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction fees. As noted above, the Advisor’s recommended Custodian typically does not charge securities transaction fees for ETF and equity trades in Client accounts, but may charge for mutual funds and other types of investments. As such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. C. Fees Wealth management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior quarter. Wealth management fees range from 0.75% to 2.00% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The Advisor has a minimum annual fee of $10,000. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Cohen Capital will be independently valued by the Custodian. In addition, all fees paid to Cohen Capital for wealth management services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and exchange-traded funds (“ETFs”) to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. Securities transaction fees for Client-directed trades will be charged back to the Client. In connection with the discretionary Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 16 investment management services provided by Cohen Capital, the Client may incur other costs assessed by the Custodian or other third parties, other than the costs noted above, such as wire transfer fees, fees for trades executed away from the Custodian and other fees. The Advisor does not control nor share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged by Cohen Capital to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure). D. Compensation Cohen Capital is the sponsor and portfolio manager of this Wrap Fee Program. Cohen Capital receives investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management of the Client’s account[s]. Item 5 – Account Requirements and Types of Clients Cohen Capital offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses. Cohen Capital generally does not impose a minimum relationship size, but does have a minimum annual fee of $10,000, which may be reduced at the sole discretion of the Advisor. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional information. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection Cohen Capital serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. Related Persons Cohen Capital personnel serve as portfolio managers for this Wrap Fee Program. Cohen Capital does not serve as a portfolio manager for any third-party Wrap Fee Programs. Performance-Based Fees Cohen Capital does not charge performance-based fees for its investment advisory services. The fees charged by Cohen Capital are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Cohen Capital does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Supervised Persons Cohen Capital Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure. Methods of Analysis Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the research and analysis methods employed by the Advisor. Risk of Loss The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 17 ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks. Proxy Voting Cohen Capital does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. Should the Client direct proxy statements to the Advisor, the Advisor is not authorized or obligated to act on such voting matters. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 18 Item 7 – Client Information Provided to Portfolio Managers Cohen Capital is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see the Cohen Capital Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers Cohen Capital is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at Cohen Capital. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations There are no legal, regulatory or disciplinary events involving Cohen Capital or its management persons. Cohen Capital values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 339112. Please see Item 9 of the Cohen Capital Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the background of the Advisor and its Advisory Persons. Other Financial Activities and Affiliations Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure). B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Cohen Capital has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons subject to Cohen Capital’s compliance program (our “Supervised Persons”). Complete details on the Cohen Capital Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Review of Accounts Client accounts are monitored on a regular and continuous basis by Advisory Persons of Cohen Capital under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure. Other Compensation Participation in Institutional Advisor Platform As noted in item 12, Cohen Capital has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders wealth management services to Clients that maintain assets at Fidelity The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 19 provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. Client Referrals from Solicitors The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Financial Information Neither Cohen Capital, nor its management, have any adverse financial situations that would reasonably impair the ability of Cohen Capital to meet all obligations to its Clients. Neither Cohen Capital, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Cohen Capital is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Cohen Capital Advisors, LLC 303 East Wacker Drive, Suite 2103, Chicago, IL 60601 Phone: (312) 477-3155 | Website: https://coheninvest.com Page 20

Frequently Asked Questions