CORIENT PRIVATE WEALTH LLC

CORIENT PRIVATE WEALTH LLC Form ADV Part 2A 830 Brickell Plaza, Suite 4800 Miami, FL 33131 (305) 735-2020 October 6, 2025 This Brochure provides information about the business practices and qualifications of Corient Private Wealth LLC, d.b.a. Corient. If you have any questions about the contents of this Brochure, please contact Corient Compliance at (305) 735-2020 or compliance@corient.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Corient is registered with the SEC as an investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. Additional information about Corient is available on the SEC’s website at www.adviserinfo.sec.gov/firm/summary/319448.  Item 2- Summary of Material Changes This section provides a Summary of Material Changes (the “Summary”) reflecting any material changes to this Brochure since our last required “annual update” filing. In the event of any material changes, the summary is provided to all clients within 120 days of our fiscal year-end, and a copy of this complete Brochure is available at any time upon request. Since Corient’s last annual update was filed on March 31, 2025, Corient notes the following material changes: Item 4 - updated to reflect changes in ownership Item 12 - updated Brokerage Practices to reflect receipt of support services from Charles Schwab and Fidelity Item 17 - updated to reflect changes to Corient’s proxy voting policies, effective October 1, 2025 2  Item 3- Table of Contents Item 1- Cover Page ................................................................................................................................ 2 Item 2- Summary of Material Changes .................................................................................................... 2 Item 3- Table of Contents ...................................................................................................................... 3 Item 4 - Advisory Business ...................................................................................................................... 4 Item 5 - Fees and Compensation ........................................................................................................... 6 Item 6 - Performance Based Fees and Side-by-Side Management ........................................................... 8 Item 7 - Types of Clients ........................................................................................................................ 8 Item 8 - Methods of Analysis, Investment Strategies and Summary of Risk .............................................. 8 Item 9 - Disciplinary Information ........................................................................................................... 20 Item 10 - Other Financial Industry Activities and Affiliations ................................................................... 20 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading................ 21 Item 12 - Brokerage Practices ............................................................................................................... 22 Item 13 - Review of Accounts ............................................................................................................... 24 Item 14 - Client Referrals and Other Compensation ............................................................................. 24 Item 15 - Custody ............................................................................................................................... 26 Item 16 - Investment Discretion ........................................................................................................... 26 Item 17 - Voting Client Securities ......................................................................................................... 26 Item 18 - Financial Information ............................................................................................................ 27 3  Item 4 - Advisory Business Corient Private Wealth LLC (“Corient” or the “Firm”) is a registered investment adviser based in Miami, Florida, with offices around the United States. Corient was established in 2022. INVESTMENT ADVISORY SERVICES Corient provides financial planning and investment advisory services to individuals, corporations, trusts, pension and profit-sharing plans, charitable organizations, and other entities. into consideration each clients Corient Private Wealth Advisors (“Wealth Advisors”) provide tailored investment management services taking individual needs and circumstances before making any recommendations. These tailored services are developed through in-depth discussions and a financial planning process, in which goals and objectives are established based on each client's unique circumstances. Clients may request reasonable restrictions regarding the management of their accounts, including restricting certain securities or types of investments by providing written instructions to their Wealth Advisor. Wealth Advisors manage client accounts on a discretionary and non-discretionary basis depending on the needs of the client. When managing accounts on a discretionary basis, the client grants Corient and the Wealth Advisor the authority through their Wealth Management Agreement (“WMA”) to determine the specific securities to be purchased or sold without prior client consent. Corient also provides non-managed advisory services to clients, including among others, financial planning, reporting, and consulting services for a fixed-fee or hourly rate as agreed upon. Corient and its Wealth Advisors solely provide investment recommendations or advice but do not direct the trading. TRADITIONAL INVESTMENTS Corient offers a wide range of internally managed strategies, as well as third-party, separately managed accounts (SMA) solutions and mutual fund and exchange traded fund (ETF) models. Clients of firms that have been acquired by Corient as the result of an acquisition may have different investment strategies that were in place at the time the client entered into an advisory agreement with that firm. Corient continues to honor these arrangements for those acquired clients. RETIREMENT PLAN ASSETS Wealth Advisors can provide investment advisory services to retirement plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. Wealth Advisors are limited to the allocation of the assets among the investment alternatives available through the plan. Wealth Advisors will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify their Wealth Advisor of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Corient can also provide non-discretionary advisory services to ERISA retirement plans whereby the Wealth Advisor provides the Sponsor and the Plan with the recommended investment options for the Plan from which Plan participants can choose. 4  ALTERNATIVE INVESTMENTS Corient also offers alternative investment strategies through our affiliate Corient IA LLC (“Corient IA”) or through third-party managers. These investments carry risk and are designed for investors that meet the qualified purchaser, qualified client, or accredited investor requirements as defined by the SEC. WRAP FEE PROGRAMS Corient does not sponsor a wrap fee program. Corient does provide portfolio management services to wrap fee programs sponsored by affiliated and unaffiliated third parties. When Corient manages wrap fee accounts, Corient receives a portion of the wrap fee for our services. PERSONAL CFO SERVICES Corient Family Office LLC, an affiliate of Corient Private Wealth LLC, can provide day-to-day financial management services to clients. Examples of such services are financial management, bill pay, accounting and reporting, tax support, and lifestyle management. Clients may be charged a separate fee for these additional services. TAX PLANNING AND COMPLIANCE Corient Tax LLC, an affiliate of Corient Private Wealth LLC, can provide standalone tax planning for individuals and businesses, as well as audit support, under a separate agreement. Clients may be charged a separate fee for these additional services. TRUST SERVICES For clients in need of Trust Services, Corient offers corporate trustee services through Corient Trust Company LLC, a South Dakota chartered trust company. Corient Trust Company is an affiliate of Corient Private Wealth LLC. These services are offered through a separate agreement and fees. OWNERSHIP Corient is wholly owned by Corient Partners LLC, which is a majority owned subsidiary of CI Financial Corp through a series of intermediate entities. On August 12, 2025, MC Accelerate Holdings LP, an entity managed by Mubadala Capital LP, acquired a substantial majority of the outstanding equity of CI Financial Corp.; the remaining equity was held by Kurt MacAlpine, Partner and CEO of Corient and CEO of CI Financial Corp., who contributed his equity into the transaction structure to invest in Corient alongside Mubadala. Following completion of the transaction, Corient is an indirect majority owned subsidiary of Mubadala Capital LP, which is ultimately owned through various wholly owned intermediate entities by the Government of Abu Dhabi. Corient also has over 250 indirect minority owners comprised of individual partners working in the firm. ASSETS UNDER MANAGEMENT As of December 31, 2024, our total regulatory assets under management were approximately $143,628,532,902 of which Corient managed approximately $129,422,543,156 on a discretionary basis and approximately $14,205,989.746 on a non-discretionary basis. 5  Item 5 - Fees and Compensation INVESTMENT ADVISORY FEES The structure and level of Corient’s advisory fee will vary by client based upon the services provided and other considerations deemed relevant by Corient but typically takes the form of a percentage of assets under management and/or advisement, ranging up to 1.00% per annum. Corient, in its sole discretion, may, and does, negotiate its investment advisory fee and/or charge a flat fee based upon certain criteria (e.g., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, competition, etc.). As result, similarly, situated clients pay different fees. Each client should refer to their Wealth Management Agreement (WMA) for specific details on their fee arrangement. Fees are billed quarterly in advance based on the value of the client’s account(s) on the last day of the prior period. For clients onboarded at any time other than the first day of the quarter, fees will be prorated and included in the next quarter’s billing. There is no pro-ration or reduction for any additions or withdrawals of assets during a quarter. The WMA authorizes Corient to debit fees directly from the client’s account(s). Corient will invoice the custodian who will deduct the fee from the client's account(s). The custodian will send a statement to the client, at least quarterly, indicating the amount of the advisory fee(s) to be deducted from their account(s). For a limited number of clients, as agreed upon in writing, Corient invoices the client directly for their advisory fees. Clients of investment advisory businesses acquired by Corient will remain on their existing fee schedules, billing calculation methodology, and payment method until notice of a change in the fee or billing practice is provided to the client. Clients should refer to their applicable agreements to understand the specific billing applicable to their assets. For terminations during the calendar quarter, when fees are paid in advance, Corient will refund a portion of the client fees on a pro-rated basis for the remainder of the calendar quarter. Corient may provide portfolio management services or wealth management advice to Corient employees and their family members at a rate lower than the rates generally available to other clients. RETIREMENT PLAN FEES Fees for Retirement Plan services are paid by the Sponsor and/or from each plan participant’s account as determined by the Sponsor, in accordance with the Retirement Plan Services Agreement. Fees will be billed quarterly in arrears based on the market value of the Plan assets on the last day of the billing quarter. The maximum fee charged will be 0.75% annually with a minimum quarterly fee of $5,000.00. For terminations in the middle of a billing quarter, the Fee shall be prorated for the remainder of the billing quarter, based on the market value of the assets on the effective date of termination. FINANCIAL PLANNING FEES Financial Planning fees are negotiated and based on the depth and scope of the services to be provided. Fees 6  are billed monthly in advance on the first day of the month following the start date as determined in the Wealth Planning and Consulting Agreement. If the agreement is terminated, the client will be required to pay the balance due. If the client prepaid a portion of the fee, the unused portion of the fee will be refunded to the client. TAX SERVICES When requested by a client, our affiliate Corient Tax LLC, will provide clients with tax services, typically for an additional fee, by a separate agreement. Clients who joined through an acquisition may have these services included as part of their existing Advisory Agreement. MARGIN ACCOUNTS Wealth Advisors’ clients may also maintain a margin account, which is a brokerage account that allows investors to borrow money to buy securities. By using borrowed funds, the client is employing leverage that will magnify both account gains and losses. The unaffiliated broker charges the investor interest for the right to borrow money and uses the securities as collateral. Should a client determine to use margin, Corient will include the entire market value of the margined assets when computing its advisory fee. Accordingly, Corient’s fee shall be based upon a higher margined account value, resulting in Corient earning a correspondingly higher advisory fee. As a result, this creates a conflict of interest since Corient has an economic disincentive to recommend that the client terminate the use of margin. THIRD-PARTY INVESTMENT MANAGEMENT FEES If a Wealth Advisor recommends a third-party manager to manage a portion or all of the assets, clients will be charged a separate fee in addition to the Corient asset-based fee. These fees are disclosed in the third-party manager’s advisory agreement, prospectus, or offering memorandum, as applicable. CUSTODIAN/BROKERAGE FEES In addition to the fees described above, clients will incur separate fees by the custodian for transfers, buying and selling of securities, and other custodian fees. Transactions may be affected through a broker/dealer other than the account custodian. In these cases, the client will incur additional fees (such as a commission and/or markup/markdown) charged by the executing broker/dealer and/or separate “trade away” or prime brokerage fees by the account custodian. PRIVATE FUND FEES Corient advises private funds through our affiliate, Corient IA, for the purpose of investing in a specific investment, strategy, or a vehicle. Wealth Advisors may recommend affiliated or unaffiliated private funds. When investing in a private fund offered by Corient IA, the client will not pay a Corient management fee. The client will be responsible for fees and expenses associated with the fund, such as fund management fees, incentive allocations, and/or other performance-based fees. Clients should review the offering documents and applicable ADV’s of the fund prior to investing to understand all the fees and expenses associated with the investment. Item 6 - Performance Based Fees and Side-by-Side Management 7  Corient does not charge performance-based fees to client accounts. However, Corient could recommend investments in third-party funds or affiliated funds which, in certain circumstances, will charge performance-based fees that will be borne directly or indirectly by clients. Item 7 -Types of Clients Corient provides investment advisory services primarily to the following types of clients: Individuals, including high-net-worth individuals • • Trusts, estates, and charitable organizations • Pension and profit-sharing plans • Corporation or business entities and other entities ACCOUNT MINIMUMS Corient does not have a strict minimum client account size. However, Corient strategies have account minimums ranging from $250,000 to $5 million. Third-party managers that Corient Wealth Advisors recommend may impose more restrictive account requirements and billing practices different than Corient’s. Account minimums may be required for certain strategies or services. For private fund investments, clients should review the offering documents for qualifications and minimum subscription requirements. Item 8 - Methods of Analysis, Investment Strategies and Summary of Risk OVERVIEW Corient typically enters into discretionary agreements with clients granting Corient the authority to engage and replace, if necessary, external investment managers and select individual securities. Wealth Advisors work with Corient’s Investment Team to review clients’ existing portfolios and deliver recommendations based on a client’s individual risk tolerance, time horizon, and overall objectives. Corient is responsible for determining a client’s overall target asset allocation, selecting investments, and implementing and maintaining the portfolio. Corient may construct portfolios using a mix of cash and cash equivalents, exchange traded funds or notes, closed-end funds, mutual funds, individual equities, individual bonds, and private pooled investment vehicles or by allocating some or all of a given portfolio to a third-party separately managed account. In certain situations, Corient can invest in strategies that involve the use of other, more esoteric assets such as financial derivatives or structured notes by engaging third-party managers or directly transacting in those assets. investment opportunities and strategies Corient uses a team approach to investing. Our team model is comprised of the Corient Investment Committee, an Alternative Investments Sub-Committee and individual Investment Team members serving in various functional groups. Risk is considered at the security, strategy, manager, account, and/or portfolio level depending on a client’s objectives and recommended portfolio. Corient’s Investment Team it continuously monitors the traditional and alternative recommends. EXTERNAL INVESTMENT MANAGERS – RESEARCH AND DUE DILIGENCE 8  The external manager research team employs a structured, five-pillar approach to evaluate investment managers: Firm, Team, Philosophy, Process, and Performance. This framework focuses on identifying investment managers and strategies in a variety of investment vehicles and styles. 1. Firm: The Investment Team assesses the organization's stability, culture, and operational setup. The assessment includes the ownership structure and alignment of incentives with long-term goals to determine if the firm possesses the resources and resilience to support their Investment Teams over the long term. 2. Team: The evaluation focuses on the individuals behind the strategy, emphasizing their skills, experience, and collaboration. Insights are gathered from various sources if necessary, including analysts, institutional clients, and former employees, to obtain a complete picture of the team. 3. Philosophy: The Investment Team examines the manager’s or strategy’s objectives distinguishing factors. A well-defined and articulated philosophy provides insight into how the manager is built to perform over time. 4. Process: The Investment Team analyzes how portfolios are constructed and includes components based on the specific investment strategy in focus. Attention is paid to how proven, consistent, easy to understand, repeatable, and adaptable the investment process is. 5. Performance: The team delves into historical performance to understand the drivers of returns. The impact of trading on performance, including turnover, brokerage and transaction costs, and taxes, is also considered. Continuous monitoring of approved managers and strategies is conducted to ensure confidence in the selections. Ongoing oversight is critical to ensure that managers adhere to their stated strategies and continue to meet performance expectations. Corient offers a platform of both equity, fixed income, and alternative investing strategies, through customized asset allocation. Corient has a goals-based customized approach to portfolio management, offering both in-house and third-party managed strategies. EQUITY STRATEGIES The equity strategies vary by mandate, all with a focus on capital appreciation as a primary objective. Philosophies include dividend-based strategies, GARP (growth at a reasonable price), socially conscious, and direct indexing. In strategies other than direct indexing, we will select individual securities based upon fundamental analysis performed by our research investment professionals. The Investment Team relies primarily on publicly available information in our analysis, supplemented by third-party research and analytical tools. FIXED INCOME STRATEGIES For our managed account fixed income strategies, our primary objective is capital preservation. Secondary objectives include providing steady income and the potential for capital appreciation. Our fixed income strategies are formed through a combined top-down and bottom-up perspective. From the top-down, we develop our economic outlook and interest rate strategy using macroeconomic and market data and trends. We will alter our duration, sector, and yield curve exposure targets based on this outlook. CORIENT INDIVIDUAL SECURITY STRATEGIES 9  Corient offers a selection of equity and fixed income strategies built using individual stocks and fixed income securities. The strategies are actively managed with the objective of providing attractive performance results over time. Responsibilities of the Individual Securities Team are divided by asset class, and each team member participates in the security analysis and portfolio construction process. EQUITY STRATEGIES Security Analysis - Corient’s Individual Security Team utilizes a bottom-up, fundamental approach to equity security analysis as the primary driver of security selection. At the core of the investment process is a focus on high-quality companies. Although quality is measured across a number of different metrics, the team focuses on the following: predictable growth of earnings and cash flow, durable returns on invested capital, strong management teams that are aligned with shareholders, and sustainable competitive advantages. Portfolio Construction - Corient offers a number of equity strategies with defined objectives and guidelines to meet clients’ investment needs. The strategies can be customized to reflect specific client preferences, including risk tolerance and exclusion of companies/industries/sectors. In general, the individual equity strategies focus on large-cap companies based in the US. The specific objectives of the strategies can broadly be defined as Core, Growth, Income, and Value. Based on each strategy’s objective, the portfolio managers select and size positions in the portfolio that they deem most appropriate to provide market returns over a full economic cycle. FIXED INCOME STRATEGIES Security Analysis - Corient’s Individual Security Team utilizes a bottom-up, fundamental approach to fixed income security analysis. For specific fixed income markets, the team also analyzes security structure, including any embedded call features, credit spreads, relative yields, and the shape of the yield curve. Portfolio Construction - Corient offers a number of fixed income strategies designed to meet clients’ investment needs based on their risk tolerance, liquidity needs, tax rate, and state of domicile. Corient’s fixed income strategies tend to focus on investment-grade rated issuers in both the taxable and tax-exempt markets. In general, the fixed income strategies are defined by their tax status, credit risk, and duration/interest rate risk. Portfolio managers seek to meet the specific objective of a strategy through security selection, asset class exposure, duration, and positioning along the yield curve. Clients that have been acquired by Corient as the result of an acquisition may have different investment strategies, based on the predecessor firm’s models that were in place at the time the client entered into an advisory agreement with that firm. Corient continues to honor these arrangements for those acquired clients. ALTERNATIVE INVESTMENT STRATEGIES/PRIVATE FUNDS These investments carry risk and are designed for investors that meet qualified purchaser, qualified client, or accredited investor requirements as defined by SEC. Private investments are not liquid and cannot be readily sold or converted to cash or other securities. Clients should consider their liquidity needs before choosing to invest. Clients should review offering documents carefully before investing. Wealth Advisors can recommend that qualified clients consider an investment in private investment funds, where appropriate. Wealth Advisors can also recommend that a client consider investing in private investment funds formed and managed by Corient’s affiliates, namely Corient IA and Segall Bryant Hamill (“SBH”). Private investment funds involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints, and lack of transparency. A complete discussion of risks is set forth in each 10  fund’s offering documents which will be provided to each client for review and consideration. Corient Private Access Corient Private Access LP ("CoPA") is Corient’s private funds solution, advised by Corient IA, for qualified purchasers and is powered by the GLASfunds platform (an affiliate of Corient Private Wealth LLC). There is a conflict of interest when a Wealth Advisor recommends a client invest in an affiliated fund because Corient and the Wealth Advisor earn additional compensation. CoPA offers a “Series” of investment strategies, with each series having a distinct investment objective and terms. Examples of representative series that are or have been offered as series of CoPA include but are not limited to: private equity, private equity secondaries, venture capital, GP stakes, private equity co- investments, distressed credit, opportunistic credit, hedge funds, natural resources, real estate, infrastructure, royalties & minerals, corporate direct lending, private CLOs, asset-backed lending, emerging market debt, real estate lending, etc. Each CoPA series may exist as open-ended portfolios, closed-end portfolios, or other portfolio investments. In pursuit of each Series of investment objectives, the investment manager may, without limitation, invest in private investment funds, separate accounts, co-investment vehicles, and other investment vehicles or accounts. The specific investment objectives of each Series will be outlined in the Series supplement and offering documentation. Corient Registered Alternatives Fund Corient Registered Alternatives Fund (“CoRA Fund”) is managed by affiliate SBH. The investment objective of the CoRA Fund is to seek long-term capital appreciation and, to a lesser extent, income. Under normal circumstances, the CoRA Fund will invest at least 80% of its net assets (plus the amount of any borrowings for investment purposes) in alternatives investments and investments with exposure to alternative investments. There is a conflict of interest when a Wealth Advisor recommends a client invest in an affiliated fund because SBH and/or Corient and the Wealth Advisor earn additional compensation. Clients should review the fund offering documents and SBH ADV 2A for more information. RISK MANAGEMENT Corient employs a risk management process to evaluate and manage the risks associated with the portfolios we oversee. Our philosophy emphasizes a thorough understanding of the drivers of risk and returns, both at the portfolio level and in comparison to relevant benchmarks. For equities, our benchmarks may include gauges such as the S&P 500, Russell 2000, Russell 3000, MSCI ACWI, and MSCI ACWI ex USA indices. The goal of our risk management process is to ensure that the risks taken in client portfolios are intentional, aligned with the investment strategy, and consistent with the client's objectives and risk tolerance. RISK EVALUATION AND BENCHMARK COMPARISON Corient evaluates portfolio risks relative to their designated benchmarks. Factor models are financial tools that may help investors identify and manage investment characteristics that influence the risks and returns of their portfolios. By using advanced factor models, we expect to identify and analyze the primary drivers of potential risk and return. These models allow us to assess how various market, sector, and style factors (such as size, value, momentum, interest rates, or credit spreads) may affect portfolio performance. We use this to gauge whether the portfolio's risk exposures are consistent with its stated objectives and whether deviations from the benchmark are deliberate and justified. 11  TOOLS USED AND METHODS OF ANALYSIS Corient uses advanced tools to manage risk and evaluate portfolios. Our tools include portfolio analytics from Bloomberg, Morningstar Direct, MSCI Wealth Manager, Aladdin, and Axioma/Qontigo. These tools use factor models, fundamental classification of underlying portfolio positions, and historical return patterns to evaluate the risks portfolios may face and to measure the potential drivers of risk and return in any given portfolio. STRESS TESTING AND DOWNSIDE RISK ANALYSIS Corient utilizes stress testing to gain a deeper understanding of the potential downside risks in client portfolios. Stress testing simulates how portfolios might perform under adverse market conditions, such as sharp declines in equity markets, rising interest rates, widening credit spreads, or geopolitical events, based on the portfolio’s underlying factor exposures at a given point in time. This analysis helps us identify vulnerabilities within the portfolio and informs decisions to mitigate excessive exposures where necessary. EQUITY PORTFOLIO RISK CONSIDERATIONS For equity portfolios, Corient assesses sector and geographical exposures to ensure that any deviations from the benchmark are intentional and within acceptable risk parameters. Sector bets are evaluated to understand their potential impact on overall portfolio performance, particularly in the context of market cycles and economic conditions. Geographical exposures are also analyzed to ensure that regional risks, such as currency fluctuations, political instability, or economic downturns, are properly accounted for and well-balanced relative to the portfolio's objectives. FIXED INCOME PORTFOLIO RISK CONSIDERATIONS For fixed income portfolios, Corient focuses on evaluating credit risk and duration risk. Credit risk analysis involves assessing the portfolio's exposure to different credit qualities, such as investment-grade bonds, high-yield bonds, mortgage-backed securities, and other major fixed income sectors. We aim to have the overall credit exposure aligns with the client's risk tolerance and objectives while avoiding undue concentration in any single issuer or sector. Corient evaluates duration risk to measure the portfolio's sensitivity to changes in interest rates. We compare the portfolio's duration to its benchmark to ensure that the interest rate risk is within acceptable bounds. Additionally, we assess the portfolio's exposure to yield curve changes, inflation expectations, and other macroeconomic factors that could impact performance. ONGOING MONITORING AND ADJUSTMENTS Risk management is an ongoing process, and Corient continuously monitors portfolio exposures to ensure they remain aligned with the portfolio’s objectives. Corient’s Investment Committee conducts a quarterly review of our asset allocation model portfolios to monitor any changes in their potential risks. We use these regular portfolio reviews and risk reports to track changes in risk exposures, sector allocations, and factor sensitivities. When necessary, we adjust to mitigate unintended risks or to align the portfolio with evolving market conditions and client goals. ALTERNATIVE INVESTMENTS IN PORTFOLIO CONSTRUCTION Corient complements many portfolios by incorporating alternative investments in the overall portfolio strategy. Alternative investments, such as private equity, hedge funds, real assets, or other nontraditional investments may offer benefits such as enhanced diversification, reduced correlation to broad market benchmarks, and the potential for higher returns. However, they also come with unique risks, including illiquidity, complexity, and higher fees. We evaluate alternative investments in the context of a client’s overall 12  portfolio, balancing their potential benefits with their risks. We consider how these alternative investments can fit within a balanced asset allocation and what investments present appropriate funding sources to keep portfolios aligned with their objectives and risk tolerances. If a strategy involves significant or unusual risks, these are discussed in detail. SUMMARY OF MATERIAL RISKS Investment activity, including investing in securities, involves risk of loss that clients should be prepared to bear. All investments carry the risk of loss, including complete loss, and there is no guarantee that any investment strategy will meet its investment, risk management objectives, or avoid losses. Any past success of a particular investment strategy or methodology does not imply or guarantee future success. Litigation Risk - Portfolio managers of underlying funds in which a client may invest may accumulate substantial positions in the securities of a specific issuer. Sometimes, a portfolio manager may engage in a proxy fight, become involved in litigation, or attempt to gain control of an issuer, and in connection with such events, significant expenses may be incurred by the underlying funds. Any such expenses incurred by an underlying fund may reduce the returns realized by the fund and its investors. Equity Instruments - Investments in equity securities involve a high degree of risk. Stock prices are volatile and change daily, and market movements are difficult to predict. Movements in stock prices and markets may result from a variety of factors, including those affecting individual companies, sectors, or industries. Such movements may be temporary or last for extended periods. The price of an individual stock may fall or fail to appreciate, even in a rising stock market. A client could lose money due to a sudden or gradual decline in a stock’s price or due to an overall decline in the stock markets. In particular, “growth” stocks can have high valuations, which, among other things, may result in the prices of growth stocks being more sensitive to changes in current or expected earnings than prices of other stocks. Accordingly, investing in growth stocks can be riskier than investing in a company with more modest growth expectations. Interest Rate Risk - The prices of and the income generated by most debt and equity securities will be affected by changes in interest rates and by changes to the effective maturities and credit ratings of these securities. In addition, falling interest rates may cause an issuer to redeem or refinance a security before its stated maturity date, which would typically result in having to reinvest the proceeds in lower-yielding securities. Inflation Risk - Security prices and portfolio returns will vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client’s future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many types of security investments to decline. Margin Risk -Margin trading involves interest charges and risks, including the potential to lose more than deposited or the need to deposit additional collateral in a falling market. A margin transaction occurs when an investor uses borrowed assets by using other securities as collateral to purchase financial instruments. The effect of purchasing a security using margin is to magnify any gains or losses sustained by the purchase of the financial instruments on margin. To the extent that a client authorizes the use of margin, and margin is thereafter employed in the management of a client’s investment portfolio, the market value of the client’s account and corresponding fee payable by the client will generally be increased, As a result, in addition to understanding and assuming the additional principal risk associated with the use of margin, clients authorizing margin are advised of the potential conflict of interest whereby the client’s decision to employ margin will correspondingly increase the advisory fee payable to Corient. 13  Fixed Income Instruments - Investment in fixed-income and debt securities such as asset- backed securities, residential mortgage-backed securities, commercial mortgage-backed securities, investment grade corporate bonds, non-investment grade corporate bonds, loans, sovereign bonds and U.S. government debt securities and financial instruments that reference the price or interest rate associated with these fixed income securities subject a client’s portfolios to the risk that the value of these securities overall will decline because of rising interest rates. Similarly, portfolios that hold such securities are subject to the risk that the portfolio’s income will decline because of falling interest rates. Investments in these types of securities will also be subject to the credit risk created when a debt issuer fails to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that debt to decline. We may also invest in debt securities which are not protected by financial covenants or limitations on additional indebtedness. Most fixed income instruments trade in over- the-counter transactions and lack the benefit of transparent exchange pricing. Bid and asks for these instruments are wider than equity securities, and trading is less frequent. These factors may cause distortions and/or volatility in the prices of fixed income-related instruments. Lastly, investments in lower- rated debt securities are also subject to the risk that the securities may fluctuate more in price and are less liquid than higher-rated securities because issuers of such lower-rated debt securities are weaker financially and are more likely to encounter financial difficulties and be more vulnerable to adverse changes in the economy. Commodities - The value of commodities investments will be affected by overall market movements and factors specific to a particular industry or commodity, such as weather, embargoes, tariffs, health, political, international, and regulatory developments. Economic and other events (whether real or perceived) can reduce the demand for commodities, which may reduce market prices and cause the value of a client portfolio to fall. The frequency and magnitude of such changes cannot be predicted. Exposure to commodities and commodities markets may subject a client portfolio to greater volatility than investments in traditional securities. No active trading market may exist for certain commodities investments, which may impair the ability to sell or to realize the full value of such investments in the event of the need to liquidate such investments. In addition, adverse market conditions may impair the liquidity of actively traded commodities investments. Certain types of commodities instruments (such as total return swaps and commodity-linked notes) are subject to the risk that the counterparty to the instrument will not perform or will be unable to perform in accordance with the terms of the instrument. Derivatives - The use of derivatives can lead to losses because of adverse movements in the price or value of the asset, index, rate, or instrument (collectively, the reference instrument) underlying a derivative, due to failure of the counterparty or tax or regulatory constraints. In this context, derivatives include but are not limited to futures, forwards, options, participatory notes, warrants, and other similar instruments that may be valued based upon another or related asset. Derivatives can create economic leverage in a client portfolio, which magnifies the portfolio’s exposure to the underlying investment. Derivatives risk may be more significant when derivatives are used to enhance returns or as a substitute for a position or security, rather than solely to hedge the risk of a position or security held by a client portfolio. Derivatives for hedging purposes may not reduce risk if they are not sufficiently correlated to the position being hedged. A decision as to whether, when and how to use derivatives involves the exercise of specialized skill and judgment, and a transaction may be unsuccessful in whole or in part because of market behavior or unexpected events. 14  Derivative instruments may be difficult to value, may be illiquid, and can be subject to wide swings in valuation caused by changes in the value of the underlying instrument. If a derivative counterparty is unable to honor its commitments, the value of a client portfolio may decline and/or the portfolio could experience delays in the return of collateral or other assets held by the counterparty. The loss on derivative transactions can exceed the initial investment. Certain strategies use derivatives extensively. Derivative investments also involve the risks relating to the reference instrument. ETFs - Investing in an ETF exposes a client portfolio to all the risks of ETF’s investments and subjects it to a pro rata portion of the ETF’s fees and expenses. As a result, the cost of investing in ETF shares may exceed the cost of investing directly in its underlying investments. ETF shares trade on an exchange at a market price which may vary from the ETF’s net asset value. ETFs may be purchased at prices that exceed the net asset value of their underlying investments and may be sold at prices below such net asset value. Because the market price of ETF shares depends on market demand, the market price of an ETF may be more volatile than the underlying portfolio of securities the ETF is designed to track. A client account may not be able to liquidate ETF holdings at the time and price desired, which may impact performance. ETNs - An ETN is a debt obligation, and its payments of interest or principal are linked to the performance of a referenced investment (typically an index). ETNs are subject to the performance of their issuer and may lose all or a portion of their entire value if the issuer fails or its credit rating changes. An ETN that is tied to a specific index may not be able to replicate and maintain exactly the composition and weighting of the components of that index. ETNs also incur certain expenses not incurred by the referenced investment and the cost of owning an ETN may exceed the cost of investing directly in the referenced investment. The market trading price of an ETN may be more volatile than the referenced investment it is designed to track. ETNs may be purchased at prices that exceed net asset value and may be sold at prices below such value. A client account may not be able to liquidate ETN holdings at the time and price desired, which may impact performance. Currency - In general, the value of investments in, or denominated in, foreign currencies increases when the US dollar is weak (i.e., is losing value relative to foreign currencies) or when foreign currencies are strong (i.e., are gaining value relative to the US dollar). When foreign currencies are weak, or the US dollar is strong, such investments will decrease in value. The value of foreign currencies as measured in US dollars may be unpredictably affected by changes in foreign currency rates and exchange control regulations, application of foreign tax laws (including withholding tax), governmental administration of economic or monetary policies (in the US or abroad), intervention (or the failure to intervene) by US or foreign governments or central banks, and relations between nations. A devaluation of a currency by a country’s government or banking authority will have a significant impact on the value of any investments denominated in that currency. Currency markets are not as regulated as securities markets and currency transactions are subject to settlement, custodial and other operational risks. Exposure to foreign currencies through derivative instruments will also be subject to the Derivatives Risks described below. Emerging Markets - Investment markets in emerging market countries are typically smaller, less liquid, and more volatile than developed markets, and emerging market securities often involve greater risks than developed market securities. Such risks may be even greater in frontier markets. Trading in foreign, emerging and frontier markets usually involves higher expenses than trading in the US. A client portfolio 15  investing in these markets may have difficulties enforcing its legal or contractual rights in a foreign country. Depositary receipts are subject to the risks associated with investing directly in foreign securities, including political and economic risks. While American Depository Receipts (ADRs) are denominated in US dollars, they are still subject to currency exchange rate risks. ADRs are traded on US market hours, which do not match the local markets. Due to this, ADR prices are also subject to exchange rate fluctuations and market information outside of local market hours. Real Estate - Real estate investments are subject to risks associated with owning real estate, including declines in real estate values, increases in property taxes, fluctuations in interest rates, limited availability of mortgage financing, decreases in revenues from underlying real estate assets, declines in occupancy rates, changes in government regulations affecting zoning, land use, and rents, environmental liabilities, and risks related to the management skill and creditworthiness of the issuer. Companies in the real estate industry may also be subject to liabilities under environmental and hazardous waste laws, among others. REITs must satisfy specific requirements for favorable tax treatment and can involve unique risks in addition to the risks affecting the real estate industry. Funds are generally not eligible for a deduction from dividends received from REITs that are available to individuals who invest directly in REITs. Changes in underlying real estate values may have an exaggerated effect to the extent that investments are concentrated in particular geographic regions or property types. Restricted Securities - Unless registered for sale to the public under applicable federal securities law, restricted securities can be sold only in private transactions to qualified purchasers pursuant to an exemption from registration. The sale price realized from a private transaction could be less than the investor’s purchase price for the restricted security. It may be difficult to identify a qualified purchaser for a restricted security held by an investor and such security could be deemed illiquid. It may also be more difficult to value such securities. Dividend Strategies - Clients invested in strategies designed to invest in dividend paying securities may be subject to certain risks. These include issuers which have historically paid dividends reducing or ceasing to pay dividends in the future, which may additionally negatively impact the price of the security. In times of economic stress, many issuers may reduce or eliminate dividends, impacting our ability to execute our desired strategy. Income Strategies - A portfolio’s ability to generate income will depend on the yield available on the securities held by the portfolio. In the case of equity securities, changes in the dividend policies of companies held by a client portfolio could make it difficult for the portfolio to generate a predictable level of income. The use of dividend-capture strategies to generate income will expose a client portfolio to higher portfolio turnover, increased trading costs and the potential for capital loss or gain, particularly in the event of significant short-term price movements of stocks subject to dividend capture trading. Responsible Investing and ESG - Clients utilizing responsible investing strategies and environment, social responsibility, and corporate governance (ESG) factors may underperform strategies which do not utilize responsible investing and ESG considerations. Responsible investing and ESG strategies may operate by either excluding the investments of certain issuers or by selecting investments based on their compliance with factors such as ESG. These strategies may exclude certain sectors or industries from a client’s 16  portfolio, potentially negatively affecting the client’s investment performance if the excluded sector or industry outperforms. Responsible investing and ESG are subjective by nature, and Corient may rely on analysis and ‘scores’ provided by third parties in determining whether an issuer meets our standards for inclusion or exclusion. A client’s perception may differ from ours or a third party’s perception of how to judge an issuer’s adherence to responsible investing principles. Short Sales - A client portfolio will incur a loss as a result of a short sale if the price of the security sold short increases in value between the date of the short sale and the date on which the portfolio purchases the security to replace the borrowed security. In addition, a lender may request, or market conditions may dictate, that securities sold short be returned to the lender on short notice, and the client portfolio may have to buy the securities sold short at an unfavorable price and/or may have to sell related long positions before it had intended to do so. The client portfolio may not be able to successfully implement its short sale strategy due to limited availability of desired securities or for other reasons. The client portfolio may also be required to pay a premium and other transaction costs, which would increase the cost of the security sold short. The amount of any gain will decrease, and the amount of any loss will increase by the amount of the premium, dividends, interest or expenses the client portfolio may be required to pay in connection with the short sale. Because losses in short sales arise from increases in the value of the security sold short, the investor’s losses are potentially unlimited in a short sale transaction. Short sales could be speculative transactions and involve special risks, including greater reliance on the investment adviser’s ability to accurately anticipate the future value of a security. Concentration - A strategy that concentrates its investments in a particular sector of the market (such as the utilities or financial services sectors) or a specific geographic area (such as a country or state) may be impacted by events that adversely affect that sector or area, and the value of a portfolio using such a strategy may fluctuate more than a less concentrated portfolio. In addition, certain funds and strategies are “non- diversified,” meaning they focus their investments on a small number of issuers, making them more susceptible to risks affecting such issuers than a more diversified fund or strategy. Taxes and Tax Management Strategies - The tax treatment of investments held in a client portfolio may be adversely affected by future tax legislation, Treasury Regulations and/or guidance issued by the Internal Revenue Service that could affect the character, timing, and/or amount of taxable income or gains attributable to an account. In addition, investment strategies that seek to enhance after-tax performance may be unable to fully realize strategic gains or harvest losses due to several factors. For example, market conditions may limit the ability to generate tax losses, or the tax-managed strategy may cause a client portfolio to hold a security to achieve more favorable tax treatment or to sell a security in order to create tax losses. Leverage - Certain types of investment transactions may give rise to a form of leverage. Such transactions may include, among others, borrowing, the use of when-issued, delayed delivery or forward commitment transactions, residual interest bonds, short sales, and certain derivative transactions. A client portfolio may be required to segregate liquid assets or otherwise cover the portfolio’s obligation created by a transaction that may give rise to leverage. To satisfy the portfolio’s obligations or to meet segregation requirements, portfolio positions may be required to be liquidated when it is not advantageous to do so. Leverage and borrowing can cause the value of a client portfolio to be more volatile than if it had not been leveraged, as 17  certain types of leverage may exaggerate the effect of any increase or decrease in the value of securities in a client portfolio. Leverage and borrowing may lead to additional costs to clients, including interests, fees, and other related investors. Losses on leveraged transactions can exceed the initial investment. Liquidity - A client portfolio is exposed to liquidity risk when trading volume, lack of a market maker or trading partner, large position size, market conditions, or legal restrictions impair its ability to sell investments or to sell them at advantageous market prices. Consequently, the client portfolio may have to accept a lower price to sell an investment, can be subject to additional fees for liquidity, or continue to hold it or keep the position open, sell other investments to raise cash or abandon an investment opportunity, any of which could have a negative effect on the portfolio’s performance. These effects may be exacerbated during times of financial or political stress. Market Risk - Economic and other events (whether real or perceived) such as pandemics, global health crises, war, terrorism, or other geopolitical events can increase volatility and reduce the demand for certain securities or for investments generally, which may reduce market prices and cause the value of a client portfolio to fall. The frequency and magnitude of such changes cannot be predicted. Certain securities can experience downturns in trading activity and, at such times, the supply of such instruments in the market may exceed the demand. At other times, the demand for such instruments may exceed the supply in the market. An imbalance in supply and demand in the market may result in valuation uncertainties and greater volatility, less liquidity, widening credit spreads and a lack of price transparency in the market. No active trading market may exist for certain investments, which will impair the ability of the portfolio manager to sell or to realize the full value of such investments in the event of the need to liquidate such assets. Adverse market conditions can impair the liquidity of some actively traded investments. Events such as global pandemics can cause market, employment, and societal disruptions across the world and may lead to additional geopolitical or market risk which could negatively affect markets, liquidity, and investment valuation. Government, Political, and Regulatory - US and foreign legislative, regulatory, and other government actions which may include changes to regulations, the tax code, trade policy, or the overall regulatory environment may negatively affect the value of securities within a client’s account or may affect our ability to execute our investment strategies. If compliance costs associated with such events increase, the costs of investing may increase, negatively affecting clients. Business Continuity - Adverse events such as natural disasters, outbreaks of pandemic and epidemic diseases, terrorism, acts of governments, any act of declared or undeclared war, power shortages or failures, utility or communication failure or delays, shortages, and system failures or malfunctions can have adverse effects on clients’ investments and Corient operations. Supply chain disruptions and other types of business disruptions can impact on the Corient or other service providers’ ability to service clients, including services such as trading valuations, financial markets delays, suspensions, or outages. Cybersecurity - Corient’s information and technology systems may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by its professionals, power outages and catastrophic events such as fires, tornados, floods, hurricanes, and earthquakes. Although Corient has implemented various measures to protect the confidentiality of its internal data and to manage risks 18  relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, the Firm will likely have to make a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in Corient’s operations and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information relating to clients. Corient uses third-party service providers who are also heavily dependent on computers and technology for their operations. Cybersecurity failures or breaches by us, our affiliates, other service providers and the issuers of securities in which a client invests, may disrupt, and otherwise adversely affect their business operations. This may result in financial losses to us or our clients or cause violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, litigation costs, or additional compliance costs. In addition, substantial costs may be incurred in order to prevent any cyber incidents in the future. While Corient and our service providers have established business continuity plans and risk management systems intended to identify and mitigate cyber-attacks, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. Corient cannot control the cybersecurity plans and systems put in place by service providers and issuers in which Corient invests on behalf of our clients. Corient and our clients could be negatively impacted as a result. Data Sources - Corient subscribes to a variety of third-party data sources that are used to evaluate, analyze, and formulate investment decisions. If a third party provides inaccurate data, client accounts may be negatively affected. Alternative Investments (Private Funds) Risk - In addition to the above risks, private funds, including the Private Funds, and the strategies they use include additional risks, including: • Private funds may use derivatives, short sales and/or leverage regularly, and the risks associated with those instruments and investment practices are much greater in private funds than in advisory client accounts. • Private funds are exempt from SEC registration and only available to “accredited investors” and/or “qualified purchasers” who are assumed to be sophisticated purchasers who have little or no need for liquidity from such investments and are able to withstand the loss of some or all their investment. • Limited withdrawal rights and restrictions on transfer create higher liquidity risk and investors should view an investment in private funds as a long-term investment. • Fund fees and expenses may be a higher percentage of net assets than traditional investment strategies, and investors typically are subject to performance or incentive fees or allocations in addition to management fees. • Private fund investments may be more sensitive to interest rates and include the possibility of more volatility than other investments. • Corient determines the value of investments held by the Private Funds or, if the Private Fund has invested in a third-party fund, the investment manager of that fund. The various risks briefly summarized above are not the only potential or actual risks associated with an 19  investment in any private fund. Before making any investment decision, an investor must carefully review and evaluate all of the applicable documents, and the specific disclosures regarding risk factors and conflicts of interest applicable to a particular investment. Item 9 - Disciplinary Information Corient is not aware of any disciplinary or legal events for the firm or our management persons reportable under this item that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Item 10 - Other Financial Industry Activities and Affiliations Corient affiliate, GLASfunds Holdings LLC has an application pending with the Financial Industry Regulatory Authority (“FINRA”) to register as a broker-dealer. GP III, which is wholly owned by Corient, is registered as a commodity pool operator (“CPO”) with the Commodity Futures Trading Commission (“CFTC”) and a member of the National Futures Association (“NFA”). Certain officers and employees are registered with CFTC as principals and/or associated persons. Corient affiliates may refer prospective clients or private fund investors to us. In turn, Corient may also refer clients to certain of our Canadian affiliates, and other Corient affiliates. In such cases, Corient will pay or receive direct or indirect compensation regarding the referral. Referrals of prospective clients present a conflict of interest to recommend Corient affiliates over others. Corient seeks to mitigate this conflict by limiting recommendations to those Corient believes to be in the best interest of our client and required disclosures are provided to referred prospects. Corient considers a variety of factors when considering referral recommendations, including our clients’ financial goals, objectives and portfolio, and the scope of our engagement. In all cases, it is our goal to provide our clients with the services we believe best suit their needs. CORIENT CANADIAN AFFILIATES CI Investments Inc. Assante Financial Management LTD (“AFM”), Assante Capital Management LTD (ACM), CORIENT US AFFILIATES The following entities are under common direct or indirect ownership of CI Financial: Corient Tax LLC Corient Trust Company LLC Corient Family Office LLC Segall Bryant & Hamill LLC - SEC Registered Investment Adviser (CRD # 106505) Columbia Pacific Advisors LLC - SEC Registered Investment Advisor (CRD #142725) GLASFunds Holdings LLC - SEC Registered Investment Advisors (CRD #150884) Cabana LLC (Cabana Asset Management) - SEC Registered Investment Adviser- (CRD #151418) Corient IA LLC - SEC Registered Investment Adviser (CRD #326262) 20  Corient IA LLC is affiliated with Corient Private Wealth LLC through common ownership. Wealth Advisors recommend Corient IA funds and receive an indirect economic benefit from any applicable management fees and/or incentive fees earned by the general partner or sponsor. Certain employees of Corient Private Wealth may support one or more of our related or affiliated advisers under common ownership and control. If an individual supports more than one entity, they are subject to each entity’s Code of Ethics and policies and procedures. ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING CODE OF ETHICS Corient has adopted a Code of Ethics (“the Code”) and compliance policies that require our employees to follow a high standard of business conduct and emphasize our fiduciary duty to our clients. The Code requires employees to acknowledge the Code and other compliance policies annually and when amended. EMPLOYEE PERSONAL TRADING A section of the Code is dedicated to personal trading. Employees and certain family members are required to report all personal holdings and transactions in accordance with the Code. Additionally, certain employees have been deemed Access Persons and are subject to more restrictive pre-clearance requirements for personal securities transactions. Employees are required to report and certify securities transactions in personal accounts within 30 days of each quarter end and disclose all securities holdings on an annual basis. Employees are also subject to the provisions of the CI Financial Code of Conduct. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS Wealth Advisors may recommend to clients, if appropriate, securities in which employees, related persons or affiliates have a financial interest. This includes, but is not limited to, investments in which Corient or an affiliate function as a general partner in an investment that is recommended to clients. These recommendations present a conflict of interest in that Corient and/or the Wealth Advisor have a direct or indirect financial incentive to make these recommendations. In order to address this conflict Corient requires Access Persons to obtain pre-approval of all securities transactions. Additionally, Corient has adopted trade allocation procedures to ensure that securities are allocated fairly for all clients. Corient policies prohibit employees from engaging in principal or agency cross transactions. Clients may request a copy of our Code of Ethics by contacting Compliance by email at compliance@corient.com or in writing to: Corient Compliance 830 Brickell Plaza, Suite 4800 Miami, FL 33131 ITEM 12 - BROKERAGE PRACTICES SELECTION OF BROKER-DEALERS Corient has negotiated competitive pricing and services for clients and may recommend one of our 21  preferred custodians: Charles Schwab, Fidelity, Bank of New York/Pershing, or Fiduciary Trust. Corient does ongoing monitoring of these custodians and considers many factors when evaluating custodians, including financial strength, reputation, execution capabilities, pricing, research, and service. The client will enter into a separate custodial/clearing agreement with the designated custodian. Clients may establish accounts with other qualified custodians; however, clients should be aware that the fees charged by non-preferred custodians may be higher or lower than those charged by our preferred custodians and that Corient may not be able obtain the best execution quality available. Clients, including those from firms acquired by Corient, have the option to move their account(s) to a preferred custodian of their choice. RESEARCH SOFT DOLLARS AND OTHER BENEFITS Corient receives certain products and services from broker-dealers that are customary in the course of a brokerage relationship. Those services can include investment-related research, pricing information and market data, software and other technology, compliance and/or practice management information, discounted consulting services, discounted or gratis attendance at conferences, meetings and other educational and/or social events, marketing support-including client events, and/or other products used by Corient in furtherance of its investment advisory business. Corient utilizes brokerage commissions for the purpose of obtaining research, research-related products, and other brokerage services. This practice is known as soft dollars. When Corient uses soft dollars to obtain these benefits, it is possible that the client may pay a higher cost for execution services. Use of these products generally benefits Corient clients because the products and services obtained through soft dollars assist in the formulation of investment advice. Corient receives a benefit because Corient does not have to produce or pay for this research or these services. There is a conflict of interest associated with our receipt of these benefits because Corient has an incentive to select or recommend a custodian based on our interest in receiving these benefits rather than on the clients’ interests in receiving the most favorable execution. Additionally, the research and brokerage services obtained using soft dollars can be used to serve any or all Corient clients. The brokerage and services received may disproportionately benefit one or more clients relative to others based on the amount of brokerage commissions paid by the client, the nature of the research or brokerage products and services acquired, and their relative use or value for certain accounts. Sometimes, research or brokerage services paid through a client’s commission might not be used for that client’s account. In addition, other Corient clients may receive a disproportionate benefit from economies of scale or price discounts in connection with products and services provided because of the transactions executed on behalf of a client account for which such products and services are also used. ADDITIONAL BENEFITS From time to time and consistent with our Code of Ethics and applicable regulations, Corient employees may attend conferences, due diligence meetings, and educational events paid for by product and service sponsors that are affiliated with products or services recommended to Corient clients. This includes but is not limited to (i) educational and training events for products or services, (ii) sponsored due diligence meetings and events, (iii) sales and marketing events and materials, and (iv) sponsored client and prospective client events and entertainment. This presents a conflict of interest as we or our employees 22  have an incentive to recommend those service providers who provide additional benefits to Corient or our employees to clients. In addition, Corient employees may attend or organize charitable events where donations from sponsors are given to certain charities or entities who receive services from Corient. ADDITIONAL SERVICES WE RECEIVE FROM CHARLES SCHWAB (SCHWAB) AND FIDELITY Corient has entered into agreements with Schwab and Fidelity to pay for services on our behalf (such as ACAT transfer fees). These services are not contingent upon Corient committing any specific amount of business to Schwab or Fidelity. The availability of these services benefits Corient because Corient does not have to produce or purchase them and Corient does not have to pay for these additional services. The fact that Corient receives these services from Schwab and Fidelity is an incentive for Corient to recommend the use of Schwab and Fidelity rather than making such decisions based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. Corient believes, however, that taken in the aggregate our recommendation of Schwab or Fidelity as a custodian and broker is in the best interests of our clients. Corient’s selection of custodians is supported by the scope, quality, and price received from Schwab and Fidelity and not the benefits provided. BROKERAGE FOR CLIENT REFERRALS For more information on the referrals Corient receives from third parties please see Item 14. TRADE AGGREGATION AND ALLOCATION When appropriate for the client, Corient will buy or sell an investment on behalf of more than one client account for which the transaction is allocable at one time or over a period of time, and if any order is not filled at the same price, they may be allocated on an average price basis. Similarly, if an order on behalf of more than one client cannot be fully executed under prevailing market conditions, securities may be allocated among the different clients on a basis which Corient considers equitable. When placing orders employees will seek to aggregate orders for multiple advisory clients consistent with Corient’s duty to seek best execution. Aggregation of trades is more efficient and less costly execution by enabling Corient to negotiate transactions on a consolidated basis rather than dealing with multiple smaller lots in investment types that normally trade in significant and/or pre-set blocks. CLIENT DIRECTED BROKERAGE A directed brokerage arrangement arises when a client requires that account transactions be affected through a specific broker-dealer/custodian, other than one recommended by a Wealth Advisor. In client directed arrangements, the client will negotiate terms and arrangements for their account with that broker dealer, and Corient will not be able to obtain best execution services or prices or be able to aggregate the client’s transactions for execution with orders for other accounts managed by Corient. As a result, a client will likely pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account that would otherwise be the case by utilizing one of our preferred custodians. Corient generally executes transactions for clients with the account custodian, however, transactions are at times, executed through other financial institutions or broker-dealers, when determined to be appropriate or when requested by the client. In certain circumstances, clients may be charged a flat dollar or “trade away” fee, by the custodian for each trade executed away from the custodian. 23  TRADE ERRORS When a trade error occurs, Corient has an obligation to ensure that the client is not disadvantaged. If a trade error occurs in the placement, execution, or settlement of a client’s trade, then the correction of the error can generate a gain or loss, which is isolated from the client’s account. Corient will work with all relevant parties in the trading process to promptly correct the error while ensuring that such correction does not disadvantage the client. A trade error gain to Corient will be donated to charity. ITEM 13 - REVIEW OF ACCOUNTS Wealth Advisors monitor accounts and investment strategies as part of the ongoing advisory process, with all accounts being reviewed at least annually. For clients receiving financial planning services, reviews will be conducted in accordance with the terms of the agreement. Clients are encouraged to contact their Wealth Advisor to report any changes in their needs, goals or objectives that may impact their financial situation. The client’s custodian sends statements to clients no less frequently than quarterly. Corient encourages clients to carefully review their custodian statements for accuracy. In addition to the statements and confirmations clients receive from their custodian, Corient may also provide periodic written and/or electronic reports that include details regarding investment holdings and portfolio performance. Any reports produced by Corient can vary from custodial statements, based upon accounting procedures, reporting dates, and/or valuation methodologies used for certain securities. ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION Corient has entered into various agreements regarding client referrals. Clients referred to us under a referral arrangement pay an advisory fee that is no higher than such clients would have paid if they were not referral clients. CI AFFILIATES (CANADA) CROSS-BORDER REFERRALS Corient refers Canadian clients or prospective clients to our Canadian affiliates. Our Canadian affiliates may refer an eligible client or prospective client to Corient. To facilitate this activity, Corient has entered into a bilateral cross-border agreement with the Canadian affiliates to refer eligible clients or prospective clients to one another. The party receiving a referral has agreed to pay the party making a referral a fee of the ongoing gross fees payable by the referred client in respect of the services provided to such client by the party receiving the referral. Receiving referral fees creates a conflict of interest and could affect the recommendations Corient makes to clients and prospective clients regarding their use of the Canadian affiliates. To address this conflict, Corient discloses our relationship with the Canadian affiliates and our financial interest in the referral at the time Corient makes any such referral recommendation. SCHWAB ADVISOR NETWORK SERVICE Corient receives client referrals from Charles Schwab & Co., Inc. (“Schwab”) through our participation in Schwab Advisor Network (the “SAN Program”). Schwab is a broker-dealer independent of and unaffiliated 24  with Corient. Schwab does not supervise us and has no responsibility for our management of client portfolios or other advice or services Corient provides. Corient pays Schwab a participation fee on all client accounts referred to us through the SAN Program that are custodied at Schwab. The fee Corient pays is a percentage of the fees the client owes to us or a percentage of the value of the assets in the client’s account, subject to a minimum amount. Corient pays Schwab the fee for so long as the referred client’s accounts remain custodied at Schwab. The participation and transfer fees are based on assets in accounts of our clients who were referred by Schwab and those referred clients’ family members living in the same household. Thus, Corient has a reason to recommend that client accounts and household members of clients referred through the SAN Program maintain custody of their accounts at Schwab. Corient has agreed to pay Schwab a fee if custody of a referred client’s account is not maintained by, or assets in the account are transferred from, Schwab. This fee does not apply if the client was solely responsible for the decision not to maintain custody at Schwab. This transfer fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Schwab. This transfer fee creates a conflict of interest that encourages Corient employees to recommend that referred client accounts be held in custody at Schwab. Schwab will not charge the client separately for custody for accounts referred through the SAN Program that are on an asset-based fee schedule or a transaction-based fee schedule. For those clients that choose a transaction-based fee schedule, Schwab will not charge a separate custody fee but will receive compensation from each client in the form of commissions or fees on securities trades executed through Schwab or through miscellaneous activity fees, such as account termination fees. Schwab will also receive a fee (generally greater than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab’s fees for trades executed at other broker-dealers are in addition to the other broker-dealer’s fees. As described in Item 12 - Brokerage Practices, Corient has an obligation to seek best execution of trades for client accounts. In many cases, Corient will be able to obtain lower overall trading costs for client accounts custodied at Schwab by executing trades through Schwab. Thus, trades for accounts custodied at Schwab may be executed at separate times and different prices than trades for accounts that are executed at other broker-dealers. Corient receives an economic benefit from Schwab in the form of support for products and services that are made available to us and other independent investment advisers whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which Corient would otherwise have to pay once the value of the clients’ assets in accounts at Schwab reaches a certain size. Clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, Corient benefits from the arrangement because the cost of these services would otherwise be borne directly by Corient. Clients should consider these conflicts of interest when selecting a custodian. Clients will not be charged a service fee or bear any portion of the referral fees Corient pays to Schwab. Corient has agreed not to charge clients referred through the SAN Program fees or costs greater than those charged to clients with similar portfolios who were not referred through the SAN Program. 25  OTHER SPECIALIZED PROFESSIONALS Corient is part of a group of companies that offer and provide a suite of financial services to clients and prospective clients. Employees of Corient may, and do, recommend the investment advisory and non- investment advisory services offered by Corient affiliates to their clients or prospective clients. Revenue generated as the result of an advisory Client becoming a client of a Corient affiliate, may be one of several factors used in determining overall compensation for Corient employees. This referral arrangement creates a conflict of interest in that employees are incentivized to recommend the services of Corient affiliates. ITEM 15 - CUSTODY Custody, as it applies to investment advisers, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment adviser can access or control client funds or securities, the investment adviser is deemed to have custody and must ensure proper procedures are implemented. Corient has the ability to deduct its advisory fee from a client’s custodial account. Clients are provided with an account statement directly from the custodian at least quarterly. Corient and/or certain of its employees engage in other services and/or practices (e.g., bill paying, password possession, trustee services, etc.) In addition, certain clients have established asset transfer authorizations that permit the qualified custodian to rely upon instructions from Wealth Advisors to transfer client funds or securities to third parties. These services and practices result in Corient having to undergo an annual independent surprise examination. Clients receive statements directly from the custodian(s), at least quarterly. Clients are advised to review these statements carefully and compare them with any reports provided by Corient. Clients should contact Corient immediately if accounts statements are not received from the custodian at least quarterly. ITEM 16 - INVESTMENT DISCRETION Details regarding the investment discretion that Corient exercises with respect to our clients are included in Item 4 - Advisory Business. Clients grant us this authority through their Wealth Management Agreement and their custodial paperwork. In all cases, however, Corient will only exercise discretion in a manner consistent with the goals and investment objectives outlined by the client. Clients must provide investment guidelines and restrictions to us in writing. ITEM 17- VOTING CLIENT SECURITIES Corient does not accept proxy voting authority to vote client securities for new clients. Clients will receive their proxies and other solicitations directly from their custodian. For clients acquired through an acquisition, where proxies were voted on by the previous firm, Corient will vote proxies utilizing the proxy voting services provided by Broadridge Financial Solutions. Broadridge will prepopulate proxy votes based on Broadridge’s voting guidelines which have been approved by Corient and are consistent with Corient’s fiduciary duty to our clients. A copy of Corient’s proxy voting policy is available upon request using the contact information on the cover 26  page. ITEM 18 - FINANCIAL INFORMATION Corient does not require or solicit prepayments of more than $1,200 from clients six months or more in advance. Corient is not aware of any financial condition that is likely to impair our ability to meet our contractual commitments to our clients and Corient has not been the subject of any bankruptcy proceeding. 27