FIRST HORIZON ADVISORS, INC

FIRST HORIZON ADVISORS, INC. PART 2A FORM ADV FIRM BROCHURE 4990 Poplar Ave. 3rd Floor Memphis, TN 38117 March 2025 www.firsthorizon.com CORPORATE RETIREMENT PLAN SERVICES / OTHER INVESTMENT ADVISORY SERVICES / FINANCIAL PLANNING This brochure provides information about qualifications and business practices of First Horizon Advisors, Inc. If you have any questions about this brochure, please contact us at 901-818-6065 or 1-800-300-0987. 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. First Horizon Advisors, Inc. is registered with the SEC as a registered investment adviser. Additional information about First Horizon Advisors, Inc. is available on the Securities and Exchange Commission website at www.adviserinfo.sec.gov. References to First Horizon Advisors, Inc. as a “registered investment advisor” or as being “registered” does not imply a certain level of skill or training. AMH/45241.v2  (Item 2) MATERIAL CHANGES At least annually, we will provide you a summary of the material changes made to our Firm Brochure or a complete copy of the updated Firm Brochure. At any time, you can request a complete copy of the brochure by contacting us at 901-818-6065 or 1-800-300-0987. This section describes the material changes made to our Firm Brochure since the last update of the Firm Brochure in October 2024. SUMMARY OF MATERIAL CHANGES ( Item 5) Services, Fees and Compensation- Financial Benefits and Conflicts of Interest- Investment Professional Compensation has been updated to add the following as an incentive that may be paid to an FA or IAR when employed by the Advisor: loan along with an incentive plan to provide for repayment of the loan - ( Item 5) Services, Fees and Compensation- Financial Benefits and Conflicts of Interest- First Horizon Bank Compensation has been revised to add the following: Certain Retail Bank employees participate in a bonus program which is based upon revenue generated from the products or services , including investment advisory services obtained by Bank clients assigned to the employee’s branch location. These employees are eligible to receive a payment of a fixed amount which may increase or decrease based upon the percentage of the target revenue achieved. AMH/45241.v2 2  TABLE OF CONTENTS Page Number (Item 3) (Item 1) Cover Page 1 (Item 2) 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 10 (Item 7) Types of Clients 10 (Item 8) Methods of Analysis, Investment Strategies and Risk of Loss 10 (Item 9) Disciplinary Information 14 (Item 10) Other Financial Industry Activities and Affiliations 16 17 (Item 11) Code of Ethics, Participation or Interest in Client Transactions and Personal Trading (Item 12) Brokerage Practices 18 (Item 13) Review of Accounts 19 (Item 14) Client Referrals and Other Compensation 20 (Item 15) Custody 20 (Item 16) Investment Discretion 20 (Item 17) Voting Client Securities 20 (Item 18) Financial Information 21 AMH/45241.v2 3  ADVISORY BUSINESS (Item 4) First Horizon Advisors, Inc. (formerly known as FTB Advisors, Inc.) is the successor-in-interest to First Tennessee Advisory Services, Inc. (“FTAS”). FTAS was organized in 2007 as a wholly owned subsidiary of First Tennessee Bank National Association, now known as First Horizon Bank (the “Bank”). The Bank is a wholly owned subsidiary of First Horizon Corporation (“FHC”), a financial services holding company. FHC is a publicly held company. On June 3, 2013, FTAS merged with and into its affiliated broker-dealer, First Tennessee Brokerage, Inc., and the combined entity was renamed FTB Advisors, Inc. In October 2019, FTB Advisors, Inc. changed its name to First Horizon Advisors, Inc. Our services are provided by a Financial Advisor (“FA”), Investment Advisor Representative (“IAR”) or a member of our Investment Services team (collectively, “Investment Professionals” or “ IPs” and each an “Investment Professional” or “IP” ). Investment management services provided by the Advisor include the following: • Managed Account Solutions Program (“MAS Program”) including the following account options:  First Horizon Advisors Model Portfolio Accounts  Adviser Model Managed Accounts  Adviser Directed Unified Managed Accounts  Separately Managed Accounts  Fund Strategist Portfolio Accounts  WealthBuilder Model Accounts • Corporate Retirement Plan Services • Other Investment Advisory Services • Financial Planning Services. The MAS Program is a wrap account program which includes the various investment management account options identified above. The Advisor is the MAS Program sponsor and Envestnet Asset Management, Inc. and its affiliates (“Envestnet”) provide certain investment management and administrative services for the MAS Program. The Advisor provides portfolio management services for certain account options within the MAS Program and receives a portion of the wrap fee for its services. MAS Program clients receive a separate wrap fee brochure which describes the MAS Program account options and other important information including the fees the Advisor receives for providing services to the wrap accounts. For First Horizon Advisors Model Portfolio Accounts, the Advisor will typically purchase and sell the same securities at the same time for all accounts utilizing the same investment strategy. When providing Other Investment Advisory Services, the Advisor will take into consideration individual client needs such as the client’s tax situation and holdings outside of the client’s account. All IPs provide these services. AMH/45241.v2 4  Corporate Retirement Plan Services (“CRP Services”) are provided to pension and savings plans including ERISA plans, government plans, and church plans. CRP Services include: recommendations of investment options to be used for the plan • search and recommendations of investment managers for management of plan assets • • assistance in selection of plan service providers • ongoing review and reporting concerning selected investment managers and investment options • employee education and plan enrollment services • benchmarking service to help determine plan costs vs. that of peer plans • assist in the preparation of investment policy statement • search and recommendation of Qualified Default Investment Alternative (“QDIA”) The Advisor may also provide discretionary investment management services to a plan. The client enters into an agreement with the Advisor which describes specific CRP Services to be provided to the client. These services are provided by certain FAs who are designated as Corporate Retirement Specialists. to understand Other Investment Advisory Services are provided on a discretionary or non-discretionary basis. Unless otherwise specified in the client agreement, these services involve providing ongoing investment advice. Services available include a review of the current investment portfolio and a investment objectives and the current financial situation, consultation recommendations for the client to consider. The client agreement identifies the specific services to be provided to a client. The Advisor develops an investment policy for the client or reviews an existing investment policy in order to recommend an appropriate asset allocation. Additional services include the selection of securities or managers, monitoring of portfolio risk adjusted performance, progress towards or changes in objectives as well as providing performance reporting and economic updates. Where the Advisor recommends investment managers for an account, the arrangement will be provided through a sub-manager relationship with the Advisor. Under a sub- manager arrangement, the Advisor has authority to terminate a sub-manager and to replace the current sub-managers with another sub-manager. These services are provided by FAs and IARs. Other Investment Advisory Services and CRP Services are tailored to meet the specific needs of a client. These needs are often outlined in a written investment policy statement or similar documentation for the account or identified in the agreement between the client and the Advisor for the services. A client can impose restrictions on investing in certain types of securities. Total assets managed on a discretionary basis as of December 31, 2024, were $10,066,599,359. Total assets managed on a non-discretionary basis were $ 3,550 ,935,412. as of December 31, 2024. Financial Planning. Certain FAs provide financial planning services to their clients. These services include the following steps: AMH/45241.v2 5  • The FA will provide you with the necessary tools or documents to assist you in gathering your financial information and defining your short and long term goals. The FA can assist you in this process. • After the information has been received the FA will organize and review the data using software licensed from a third-party. • Your FA may contact you to verify the accuracy of the data and allow you to validate the assumptions and information you have provided. • Using the software, the FA will analyze the data and assumptions provided , and review alternative strategies or courses of action to meet your immediate and long-term goals and objectives . This is usually an interactive process with your FA which involves you and your FA reviewing and discussing potential outcomes, and risks and assumptions for the alternative strategies . • Based upon the strategy selected, the FA will make recommendations to implement the strategy. The recommendations may include investment portfolio allocations, life insurance coverage, disability insurance coverage, education funding options; and estate planning strategies. The strategy and plan recommendations will be provided to you in written or electronic form. The plan recommendations will be based upon the information you provided your FA. You should validate all information and assumptions you provide us in preparing your financial plan. A change in any information provided in the data gathering process could result in a change in your plan recommendations. You will make all decisions regarding implementing your plan. FAs will identify products and services that are available from the Advisor or its affiliates to implement the plan recommendations. However, you are under no obligation to purchase services or products through the Advisor or its affiliates to implement the plan recommendations. If you chose to implement any recommendations by using products or services available from the Advisor or its affiliates, your FA will receive compensation from your purchase of the products or services. Please see (Item 5) – Fees and Compensation - Compensation, Financial Benefits and Conflicts of Interest. FEES AND COMPENSATION (Item 5) Fees for Advisory Services Other Investment Advisory Services and CRP Services may be provided for a fixed fee and may include a one-time review of an existing plan or portfolio, and subsequent recommendations concerning investment options or plan service provider changes. This fee is stated in the agreement between the client and the Advisor, and is negotiable. The factors considered in determining the fee include the estimated time involved, scope of the services requested, and resources utilized to deliver services. Fixed consulting fees for Other Investment Advisory Services are typically billed to the client upon completion of the services. Services that include ongoing or periodic monitoring, review and/or performance reporting of investment managers or investment options and meetings with the client or a plan’s responsible party(ies) are provided for an annual fee based upon the market value of the plan or account assets. AMH/45241.v2 6  Annual fees for these services range from .25% to 1.25%, but are negotiable. When these services are provided to fixed income portfolios, the fees will range from .10% to 1.25%, but are negotiable. The factors considered in determining the fee include the number of managers involved, total plan or account assets, and resources required to provide the services. These fees are billed quarterly in arrears, and are calculated based upon the value of the plan or account assets as of the last business day of the quarter or the average value of the plan assets during the quarter. The value of the plan or account assets for purposes of calculating the fee is determined by the custodian or as otherwise agreed to by the client and the Advisor in the services agreement. Fees for CRP Services may include both a fixed fee and an annual asset based fee. Fees for CRP Services are billed directly to the client unless the client elects and the plan allows to have the fees billed to the Plan and deducted from Plan account(s). Fees for Other Investment Advisory Services are typically deducted from the custody account. Financial Planning. There is no charge for financial planning services provided by your FA. After completion of your plan, the FA may recommend to you that you purchase products or services from the Advisor or its affiliates to implement your plan. If you chose to implement any recommendations by using products or services available from the Advisor or its affiliates, your FA will receive compensation from your purchase of the products or services from the Advisor or its affiliates. Please see “Compensation, Financial Benefits and Conflicts of Interest” below for additional information concerning compensation and financial benefits related to our services. Other Charges and Expenses. The fees charged for investment management services do not cover certain charges associated with securities transactions in clients’ accounts such as brokerage commissions, mark-ups or mark-downs. In addition, the client will pay a ticket charge for each transaction executed for the client’s account. The amount of the ticket charge is described in the investment management agreement between the client and Advisor. See (Item 12) Brokerage Practices below. The fees also do not include the internal charges and fees imposed by mutual funds and closed-end funds, unit investment trusts, exchange-traded funds (“ETF”) or real estate investment trusts. These fees and charges include operating expenses, management fees, and redemption fees, 12b-1 fees and other fees and expenses. These fees and charges are described in the appropriate prospectus, offering document, or other regulatory filings concerning the investment. The fees do not cover custody fees that are charged to clients by the custodian. A custodian may charge a minimum account fee. The fees do not include brokerage fees or other transaction costs. See (Item 12) Brokerage Practices below. Clients will be charged for specific account services, such as account transfer, fees (ACAT) and for other optional services elected by clients. Fees do not include account service fees such as individual retirement account trustee or custody fees, tax- qualified retirement plan account fees or termination fees for retirement accounts. For accounts custodied at National Financial Services, LLC (“NFS”), if you incur any of the following charges or fees, the Advisor will retain a portion of the fee charged to your account for the services: ACAT, margin interest, bounced check, stop payment, transfer and ship (Direct Registration System Eligible) and wire fees (except wire fees charged to IRAs). Compensation, Financial Benefits, and Conflicts of Interest AMH/45241.v2 7  Investment Professional Compensation. An FA or IAR’s compensation depends upon the products and services that the IP sells. Our compensation plans are subject to change at any time. Compensation for an FA or IAR is based upon total fees, commissions and other revenue paid to the Advisor for products and services the FA or IAR sells. This is referred to as the “production”. The FA or IAR is paid a percentage of their total production each month. This is referred to as the “pay-out rate”. An FA or IAR will receive either a fixed pay-out rate or a pay-out rate that will increase as the FA’s or IAR’s total production increases over the compensation period. FAs or IARs who work on a team will have a fixed pay-out rate. In this case, the pay-out rate does not change. Members of the team determine the amount of the total pay-out each team member will receive. An FA or IAR may also receive a fixed pay-out rate if a fixed pay-out rate is provided for in the FA’s or IAR’s individual incentive plan. An FA or IAR receives a minimum guaranteed draw. The FA or IAR receives a pay-out as described above only if the pay-out exceeds the monthly draw. The Brochure Supplement for your FA or IAR contains additional information concerning the compensation your FA or IAR receives. Certain costs that the firm incurs to support an FA, an FA team, or an IAR are deducted from the total production. However, these charges will be waived if the FA, FA team; or, IAR meets a specified production level. On occasion, the Advisor provides incentive compensation to an FA or IAR when employed by the Advisor. These incentives can include one or more of the following: − forgivable draw which allows the FA or IAR to receive a pay-out even if the pay- out does not exceed the draw fixed pay-out percentage of production for a set time period loan along with an incentive plan to provide for repayment of the loan − one-time upfront payment − − Employees of the Advisor who supervise FAs and IARs are eligible to receive quarterly and annual bonuses. Quarterly bonuses are based upon a net-profit margin calculation which includes the revenue and expenses associated with the offer and sale of wealth management products and services, including revenue received from the investment management services described in this Brochure. The annual bonus is based upon revenue associated with the offer and sale of wealth management products and services, including revenue received from the investment management services described in this Brochure, as well as other factors. First Horizon Bank Compensation. The Advisor has entered into a Solicitation Agreement with the Bank in order to permit Bank employees to refer clients to the Advisor in exchange for compensation. If a licensed Bank employee refers a client to the Advisor and the client opens an investment management account, the Advisor will pay the Bank employee a portion of the investment advisory fees received from the account. Client Relationship Managers, including Private Client Relationship Managers, participate in a bonus program. Payments under the program are based upon multiple factors, including revenue growth associated with products and services obtained by the Relationship Manager’s clients from the Bank and its affiliates, including investment management services from the Advisor. Certain Retail Bank employees participate in a bonus program which is based upon revenue generated from the products or services , including AMH/45241.v2 8  investment advisory services obtained by Bank clients assigned to the employee’s branch location. These employees are eligible to receive a payment of a fixed amount which may increase or decrease based upon the percentage of the target revenue achieved. These arrangements provide an incentive for Bank employees to refer their clients to the Advisor to obtain investment management services. The Advisor addresses this conflict of interest through this disclosure and the account reviews as described in (Item 13) Review of Accounts. Investment Services team members receive a salary and bonus. The bonus is not based upon the products sold to clients. Diamond Circle. Each year, we hold a conference that recognizes our highest producing IPs. The conference includes training sessions, an awards banquet, and travel and related expenses for attendees. We establish the criteria for attendance, including the number of invitees and the required production level for the awards. The conference is not a reward for the sale of any specific product or service. For more information concerning compensation of FAs and IARs related to Trust Division referrals and First Horizon Bank referrals, please see (Item 10) Other Industry Activities or Affiliations – First Horizon Bank Trust Division and First Horizon Bank. Conflicts of Interest. Your FA or IAR receives compensation from the Advisor when you obtain advisory services as described in this brochure. The amount of this compensation is based upon the fee charged for the services. Therefore, your FA or IAR takes into consideration this compensation arrangement when your fee is negotiated . Your IP separately negotiates fees for each advisory account that is opened. Therefore, negotiated fees for the same type of services will vary by client and by IP. Advisor addresses this conflict of interest through this disclosure and the Account reviews as described in (Item 13) Review of Accounts. Brokerage and Advisory Accounts. Most of our IPs provide both brokerage services and investment advisory services. Your IP will orally disclose whether they provide both services or just investment advisory services. There are important differences in the services you receive and the fees you will pay depending upon which type of account you open. When recommending the type of account and services to you, your IP will consider your trading activity, desire for account monitoring, information and reporting requirements, and other information. When you open a brokerage account, we will receive compensation based upon the product we sell you. This is called “transaction based compensation”. When you open an advisory account, you pay an ongoing fee based upon the value of the account. The fee is paid quarterly. Due to the difference in how we are paid for these services and whether your IP is an IAR or an FA, your IP has a financial incentive to recommend one type of account over the other type of account. An advisory account is a fee based account which results in ongoing quarterly revenue credited to an FA’s or IAR’s production. Brokerage accounts result in revenue credited to the FA’s production at the time the transaction is executed. Some brokerage products also pay ongoing fees known as trail fees, which will be credited to the FA’s production on a monthly or quarterly basis. An IAR does not offer brokerage services or insurance products. Therefore, your IAR has an incentive to recommend an advisory account rather than refer you to an FA or third-party to consider other products or services that may meet your financial needs. The Advisor addresses this conflict of AMH/45241.v2 9  interest through this disclosure and the Account reviews as described in (Item 13) Review of Accounts. Sponsor Payments. Custodians, mutual fund companies, investment advisors, and other service providers or product providers that provide products or services to First Horizon Advisors, Inc. (collectively, “Sponsors”) will provide certain financial benefits to the Advisor and/or an IP. Sponsors will provide educational training or marketing support to the Advisor and its IPs. Sponsors will contribute to the cost of conferences or meetings attended by some or all of the IPs. Such conferences and meetings include educational and training sessions as well as promotion of the other services provided by Advisor. Some Sponsors will bear the expense for an IP to attend due diligence trips at the Sponsors’ offices or other locations. All or a portion of the costs of certain client events will be paid for by a Sponsor. Products and services provided by the Sponsors help the Advisor and its IPs to manage and administer client accounts. The Advisor and the IPs will use such products and services for advisory accounts as well as other types of accounts and products offered by the Advisor. Sponsors pay for occasional meals and entertainment for and provide promotional items to IPs. These benefits help build relationships which could lead to sales of the Sponsor’s products or services to you. We address this conflict of interest through this disclosure and the Account reviews as described in (Item 13) Review of Accounts. See (Item 12) – Brokerage Practices below for information concerning financial benefits related to our clearing arrangement with NFS. PERFORMANCE BASED FEES (Item 6) The Advisor does not charge any performance based fees which are based on a share of capital gains or capital appreciation of the assets of a client. TYPES OF CLIENTS (Item 7) The Advisor’s investment advisory services are available to individuals, high net worth individuals, municipalities, financial institutions, pension and profit sharing plans, charitable organizations, corporations, or other business entities, trusts or estates. The minimum value of an account to obtain Other Investment Advisory Services is $100,000. The Advisor may in its sole discretion, waive the account opening minimum and accept an account with a lower market value . In the circumstances where an account has dropped to a value below the minimum, the Advisor may terminate the advisory services agreement. (Item 8) METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis – Investment Strategies. Investment Philosophy. Our investment philosophy is built around providing independent and objective needs based advice. We strive to diversify investments across asset classes, geographic regions, management styles and ownership structures. We use a top down approach designed around our client’s goals, objectives and risk tolerance. This approach considers relevant AMH/45241.v2 10  constraints as determined by the Investment Policy Statement or other account governing documents. These may include liquidity needs and timing of expected cash flow events as well as any constraints or legal considerations. Investment Strategies. The Advisor’s Investment Committee (“IC”) sets the broad investment policy based on the firm’s investment philosophy. Considerations include asset sub-class selection, creation and maintenance of a working list of investments, purchase and sale guidelines, and rebalancing guidelines. The Advisor has identified five factors that it believes to be a framework for market evolving trends. Those factors are the macroeconomic background, the trend of the market, liquidity conditions, market psychology, and fundamental valuations. Annually, the IC reviews capital market assumptions from industry sources. Based on this review, our strategic asset allocations and holdings may be modified. The Advisor does not advocate market timing. Investment Selection. To achieve proper diversification, the Advisor considers various investment categories including separate account managers, no-load mutual funds, individual large capitalization stocks, individual investment grade bonds, ETFs, as well as hybrid mutual funds, factor based funds, real assets, hedge products and other alternative investment products. The Advisor utilizes current economic, market and behavioral data as well as both internal and external sources for macro and micro-economic input, sector, industry, and individual security analysis. We also utilize third-party software program(s) and research tools. We consider mutual funds, ETFs, separate account managers and their performance, style, and risk adjusted return measures. This data is used in the analysis of portfolios and their holdings. Initial Selection of Mutual Funds. The Advisor’s analysis includes both quantitative and qualitative criteria. We seek experienced managers with a competitive performance record, stable operations, and reasonable expenses. A second layer of evaluation includes performance against relevant benchmarks and peer groups including annualized, calendar year, and rolling returns. A style analysis is performed looking for a history of consistency in the fund’s investment philosophy and style purity. Risk adjusted return measures based on Modern Portfolio Theory are also reviewed for comparison to peers. Qualitative analysis may include firm history, financial stability, service standards, regulatory infractions, and manager turnover. Ongoing Oversight. As part of the regular due diligence, the Advisor will review many of the factors listed above to identify unfavorable trends over time. If an unfavorable trend has been identified, the IC will initiate an analysis to determine what actions, if any, need to be taken. The IC may consider opportunity costs and tax implications before initiating such changes. Fixed Income. An IP constructs customized portfolios with individual bonds utilizing guidelines adopted by the IC. The fixed income process is focused on issue selection. Working from the client Investment Policy Statement, the IP will select securities that meet the established quality, duration, and maturity criteria. If permitted by the Investment Policy Statement for the account, the IP may also use ETFs, mutual funds, or individual preferred securities and other diversifying securities meeting quality and liquidity requirements. The structure of the portfolio will be adjusted from time to time based on the evaluation of current and expected interest rates, economic conditions, monetary policy, fiscal policy, and inflation. AMH/45241.v2 11  The Advisor will monitor the credit quality of account holdings utilizing third-party research and system monitoring tools. If a security drops below an investment grade rating, the firm will assess the long term implications and take appropriate action as necessary. Equities. Equities are screened for initial selection and monitored for continued inclusion in portfolios using quantitative analysis tools provided by third-party research firms. These tools employ multifactor analysis, including variables such as profitability, valuation, operating efficiencies, relative risk, manipulation of reported earnings, relative analyst sentiment, and corporate governance. Investment Risks. Risk of Loss. Investing in securities involves risk of loss of principal that a client should be prepared to bear. Asset Allocation and Diversification. Account performance depends upon allocation of assets among various asset classes and the selection of the underlying investments. There is a risk that the asset allocation, selection of asset classes and the underlying investments will cause the Account’s performance to lag relevant benchmarks or result in losses. While allocation to multiple asset classes can reduce risk, diversification cannot completely eliminate risk. Asset allocation and diversification do not guarantee a profit or protect against loss. Model Risk. Models may be similar to other model portfolios used by other investment managers. In the event of a market disruption this may result in simultaneous trading in the market by investment managers which accelerate reduction in liquidity or repricing. This can also reduce the effectiveness of a model as more investment managers seek to capitalize on market inefficiencies. Disruption in Financial Markets. Political instability, terrorism, widespread disease including pandemics and epidemics and natural or environmental disasters can be highly disruptive to the economies and the markets. Market disruptions may result in increased volatility, trading disruptions and other events which can negatively affect the value of investments held in your Account. Cybersecurity Risk. Companies, markets, investment companies, including ETFs and mutual fund companies, and service providers, like us, and NFS, use a significant amount of technologies in our/their day to day functions. As a result, these entities and those individuals who use these services, or have investments in these companies, are subject to a number of cybersecurity risks. Cybersecurity risks include, but are not limited to, compromised company, employee or client data, disruption of services, corruption or loss of data, inability to perform services (e.g. trading, valuation, issuance of reports, communications), and financial losses. Legislative and Regulatory Risk. Investments in your Account may be adversely affected by new laws or changes to existing laws or regulations. Changes to laws or regulations can impact the securities markets as a whole, specific industries, and individual issuers of securities. Other risks may include: AMH/45241.v2 12  • Underperforming a benchmark • Reinvestment risk • Inflation risk • Not meeting financial objectives such as, retirement income and college financing • Liquidity risk • Political risk • Environmental risk • Corporate governance risk Investing in individual equities introduces idiosyncratic, or specific company risks to an investor’s portfolio. The portfolios are reviewed on an ongoing basis to determine if quantitative and/or qualitative changes warrant selling a stock from the portfolio holdings. Equity investments will experience volatility and market fluctuations. While diversification may mitigate these risks, extreme fluctuations can result in a loss of principal. In a volatile market, if a sale of securities is necessitated by an unforeseen event, a loss of principal can result. Fixed Income investments include a wide range of securities with an equally wide range of risk levels. Risk in fixed income securities comes from several sources including default risk, interest rate risk, inflation risk, currency risk and liquidity risk. ETFs. An ETF is a fund that trades on an exchange, similar to stocks, and often seeks to track an index (e.g., S&P), commodity (e.g., oil, natural gas, gold, etc.), or a basket of assets like an index fund. As a result, ETFs often do not have the objective to outperform what they are tracking. However, some ETFs are actively managed and do not seek to track a certain index or basket of assets. ETFs may also have unique risks depending on their structure and underlying investments. ETFs may trade at a premium (above) or discount (below) to their net asset value (“NAV”), and may also be affected by the market fluctuations of their underlying investments. Default risk is the risk that the issuer of the bond does not make good on its obligation to pay periodic interest payments or principal at maturity. Obligations of investment grade corporations (and state and local governments) are not free from default risk, but that risk is viewed as being lower. Below investment grade bonds, i.e., junk bonds, are considered speculative in nature. Interest Rate Risk. Fixed Income securities also have interest rate risk; their market prices fluctuate up and down inversely with the prevailing interest rates. Notes and bonds purchased when interest rates are low can lose market value if interest rates rise prior to their maturity dates. As with stocks, if a sale of the bond is necessitated by an unforeseen event, a loss of principal can result. The longer the maturity of the bond held, the greater the interest rate risk, all else being equal. Inflation Risk. The inflation risk associated with bonds is twofold: the potential loss of purchasing power plus the potential for inflation to result in higher market rates of interest. As explained above, this causes the market price of a bond to decline. A portfolio manager can attempt to mitigate fixed income risks by including the use of high credit quality bonds, and investing in bonds with short to intermediate terms. AMH/45241.v2 13  Alternative securities often carry liquidity risk as well as the risk of loss of principal. Liquidity risk is an inability to sell the security in a timely fashion should cash needs arise. Financial Planning. When considering various strategies for your financial plan your FA will utilize software that conducts Monte Carlo simulations. The simulations will yield different results depending upon variables inputted, and the assumptions in the underlying calculation. The assumptions include rates of return and standard deviations of the portfolio model associated with each asset class. The assumed rates of return are based upon historical rates of return and standard deviations for certain time periods for the benchmark indices comprising the asset classes in the model portfolio. Since the market data used to generate these rates of return changes over time , your results will vary over time. Monte Carlo Analysis is a mathematical process used to implement complex statistical methods that chart probability of certain financial outcomes at certain times in the future. The charting is accomplished by generating hundreds of possible economic scenarios that could effect performance of your investments. The Monte Carlo simulation uses at most 1000 scenarios to determine the range of outcomes resulting from asset allocation choices and underlying assumptions regarding rates of return and volatility of certain asset classes. Some of these scenarios will assume favorable financial market returns , consistent with some of the best periods in investing history for investors. Some scenarios will conform to the worst periods in investing history. Most scenarios will fall somewhere in between. The outcomes using Monte Carlo simulation represent only a few of the possible outcomes. Since past performance and market conditions may not be repeated in the future, your investment goals may not be fulfilled by following advice based on the projections. DISCIPLINARY INFORMATION (Item 9) Registered investment advisers are required to disclose all material facts regarding any disciplinary events that would be material to a client’s evaluation of the Advisor and its investment staff or the integrity of the Advisor’s management. UITs. The Financial Industry Regulatory Association (FINRA) alleged that the Advisor violated FINRA Rule 2010 by failing to apply sales charge discounts to certain eligible purchases of Unit Investment Trusts (“UITS”) from June 2010 to May 31, 2015. The allegations also included failure to establish, maintain and enforce a supervisory system and written supervisory procedures reasonably designed to ensure that customers received sales charge discounts on all eligible UIT purchases (NASD Rule 3010 and FINRA Rule 2010). The Advisor entered into an Acceptance, Waiver, and Consent with FINRA on December 3, 2015, without admitting or denying the allegations. The firm identified and reimbursed all customers for discounts which had not been applied plus interest on such amounts prior to entering into the consent, and paid a fine in the amount of $125,000 to FINRA. AMH/45241.v2 14  Variable Annuities. FINRA alleged that the Advisor failed to implement an adequate supervisory system and procedures designed to reasonably ensure suitability in its Multi-share Class Variable Annuity (“VAs”) sales, including L-share contracts. FINRA also alleged that during the relevant period, January 2013 – December 2014, the firm failed to establish, maintain, and enforce an adequate supervisory system and Written Supervisory Procedures (“WSPs”) related to the sale of Multi-share Class VAs, and that the firm failed to provide sufficient training to their registered representatives and principals on the sale and supervision of Multi-share Class VAs. FINRA alleged that the WSPs and training materials failed to sufficiently provide registered representatives and principals guidance or suitability considerations for sales of different VA share classes. FINRA alleged that because of the lack of sufficient training and guidance, registered representatives did not have the tools to present potential purchases with a side-by-side comparison of the fees and surrender charges or other information detailing the potential impact of the increased fee if the L-share contract was held by the customer for a long term. FINRA also alleged that the firm failed to establish, maintain, and enforce WSPs or provide sufficient guidance or training to registered representatives and principals on the sale of long term income riders with Multi-share Class VAs, particularly the combination of L-share contracts with long-term riders. On November 2, 2016, the Advisor entered into an Acceptance, Waiver, and Consent with FINRA without admitting or denying the allegations. A fine of $250,000 was paid to FINRA. FINRA Matter No. 202006674001. FINRA found that the firm failed to supervise a registered representative and to supervise the electronic communications of its associated persons. A registered representative formerly employed by the firm engaged in an undisclosed outside business activity. This business activity was an investment club conducted through an outside brokerage account that the registered representative did not initially disclose to the firm. FINRA found that when the representative later disclosed the account to the firm, the firm did not sufficiently investigate the activity in the account. FINRA also found that the firm did not properly investigate emails sent to and from the registered representative’s firm email address, resulting in a determination that from February 2014-February 2017, the firm failed to establish, maintain and enforce written supervisory procedures with respect to the review of electronic communications. On April 13, 2022, FINRA accepted a Letter of Acceptance, Waiver, and Consent submitted by the firm in which the firm accepted these findings without admitting or denying them. The firm consented to a censure and a fine of $175,000. SEC File No. 3-22142. Without admitting or denying the findings, the Firm consented to the entry of an Order Instituting Administrative and Cease-and-Desist Proceedings in which the Securities and Exchange Commission (“Commission”) found that the Firm failed to maintain and enforce certain policies and procedures concerning structured note recommendations and exception reporting related to these recommendations. The Commission further found that that as a result of these failures, the Firm failed to maintain and enforce written policies and procedures reasonably designed to achieve compliance with the Compliance Obligation of Regulation Best Interest, found in Rule 15l-1(a)(1) of the Securities Exchange Act. The Firm paid a civil money penalty of $325,000 on September 18, 2024. AMH/45241.v2 15  OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS (Item 10) Some executive officers and members of the IC are registered representatives of First Horizon Advisors, Inc. First Horizon Advisors, Inc. provides brokerage services and custody services for certain client accounts through its clearing arrangement with NFS. Under this arrangement, the client will pay applicable commissions and fees for these services in addition to the fees charged for advisory services. When a client directs its brokerage services to First Horizon Advisors, Inc., the client forgoes any benefits in price or quality of execution obtained when a manager for an advisory account has discretion to select the executing broker for account transactions. First Horizon Advisors, Inc. regularly monitors execution price and quality of trades for its accounts. Please see Item 12 – Brokerage Practices for more information concerning conflicts of interest related to our clearing arrangement with NFS. The Advisor provides investment advisory services to Bank customers at Bank financial center locations. The Bank or its holding company provides certain support services to the Advisor, including accounting, payroll, legal and administration services. First Horizon Bank Trust Division. The Bank provides custody services through its Trust Division. A client executes a separate agreement with the Bank for custody services and is charged a separate custody fee. The Advisor provides investment management services to First Horizon Bank Trust Division. Investment management accounts are available through the Trust Division (“Agency Accounts”), and have similar strategies as advisory accounts described in this brochure. Agency Accounts are established by entering into a separate Investment Management Agreement with the Trust Division. Fees and expenses for an Agency Account will be more or less than those accounts described in this brochure. For Agency Accounts, different account opening minimums apply. Agency Accounts are administered and serviced at Trust Division locations by Trust Division personnel. IPs do not provide investment management services to Agency Accounts. The Trust Division will compensate an FA or IAR for referring a client to the Trust Division if the Trust Division opens an account, including an Agency Account, for the client. Such compensation will be based upon the fees the Trust Division receives from the trust account and it is credited to the FA’s or IAR’s production. First Horizon Bank. From time to time, the Bank will compensate an IP for referring advisory or brokerage customers to the Bank for certain financial products and services. Such compensation may be cash or non-cash compensation, and the compensation is paid by the Bank. Non-cash compensation may include prizes, travel, entertainment, and gift cards. Your IP may refer you to the Bank if you are interested in applying for a line of credit secured by your advisory account. All credit decisions for this product are made by the Bank. Your FA or IAR will not be compensated for this referral. To pledge your securities as collateral for this line of credit, you will enter into an Account Control Agreement (“ACA”) with the Bank and First Horizon Advisors, Inc. Under the terms of the ACA, you agree that you will not withdraw assets from your advisory account except with prior approval of the Bank. The ACA also states that if the Bank provides First Horizon Advisors, Inc. a notice of “exclusive control”, First Horizon AMH/45241.v2 16  Advisors, Inc. will follow instructions of the Bank with respect to your advisory account instead of instructions from you or your IP. Securities Issued by First Horizon Corporation (FHC). First Horizon Bank, the parent company of the Advisor, is a wholly owned subsidiary of FHC. The Advisor does not make recommendations to buy or sell FHC securities. (Item 11) CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics and Personal Trading. The Advisor has adopted a Code of Ethics (the “Code”) which establishes standards of fiduciary conduct for its employees, including standards that apply to personal securities transactions. The Code requires compliance with policies concerning use and disclosure of non-public information and maintaining the confidentiality of customer information. The Code also requires that certain officers of the Advisor and employees who have access to non- public information concerning purchases and sales of securities for client accounts or recommendations for such purchases or sales (“Access Persons”) report their personal securities transactions. Advisor receives reports of transactions and an annual holdings report for each Access Person. Access Persons must receive prior approval from the designated compliance officer to serve as a director of a publicly traded company. Access Persons are not permitted to: • acquire securities in an IPO or private placement without obtaining prior approval from the designated compliance officer; • execute a transaction for their own account until any orders for the same security for an • advisory client’s account has been executed or withdrawn; recommend a security transaction for an advisory account without disclosing certain personal interests in such securities; • purchase or sell any security designated by the Chief Investment Officer (CIO) or designee during any black-out period as determined by the CIO or designee. The purpose of the prohibitions described above is to avoid any benefit an Access Person may obtain from trading in a security prior to execution of a trade in the same security for a client’s account. You may obtain a copy of the Advisor’s Code of Ethics by contacting us at 901-818-6065 or 1-800-300-0987. Interest in Client Transactions. Cash awaiting investment in an Account that is custodied with NFS will be invested in a money market fund (“Mutual Fund”) available through a sweep investment program provided by NFS. Account balances held in the Mutual Funds are included in the calculation of the fee charged to your account. NFS receives fees from certain Mutual Funds for providing shareholder services, sub-accounting or other services to such Mutual Funds. NFS has agreed to pay to First Horizon Advisors, Inc. a portion of such fees it receives. The fee First Horizon Advisors, Inc. receives is based upon the average net assets of the accounts invested in the Mutual Funds through NFS. AMH/45241.v2 17  See also (Item 12) Brokerage Practices and (Item 5) Fees and Compensation for more information concerning financial benefits we receive from NFS. BROKERAGE PRACTICES (Item 12) First Horizon Advisors, Inc. does not have any arrangements with broker-dealers whereby it directly obtains research or other products or services in connection with client securities transactions. For accounts invested solely in individual fixed income securities, the Advisor will select a broker- dealer to execute trades. Fixed income transactions are generally executed by the broker-dealer on a net basis, which means the execution costs (e.g., commissions) are included in the purchase or sale price of the securities. The Advisor maintains a list of Approved Brokers for these transactions. In evaluating broker-dealers, the Advisor will consider, among other things, the financial strength and stability, trading expertise, inventory of fixed income securities, and settlement capabilities. For fixed income transactions, the Advisor will allocate orders across all accounts in equal proportions. For all other accounts, the Advisor does not select broker-dealers to execute security transactions. The Advisor requests that a client direct brokerage for transactions to a specified broker-dealer. We will recommend that a client use First Horizon Advisors, Inc. or the First Horizon Bank Trust Division for execution and custody services. Orders for transactions will be aggregated for accounts that direct brokerage through First Horizon Advisors, Inc. or through First Horizon Bank Trust Division. Aggregating orders for client accounts may provide lower execution costs per share than by trading on an individual account basis. When a client directs brokerage to First Horizon Advisors, Inc., the First Horizon Bank Trust Division or another broker-dealer, the client may not receive benefits in price or quality of execution obtained when the investment adviser has discretion to select the execution broker. In addition, by referring a client to the Trust Division or First Horizon Advisors, Inc. for these services, the Trust Division or First Horizon Advisors, Inc. will receive compensation for the execution and custody services they provide to clients. The Advisor has a conflict of interest in recommending that a client use NFS for clearing and custody services for an account. The pricing that First Horizon Advisors, Inc. has negotiated with NFS for clearing and custody services is based upon First Horizon Advisors, Inc. maintaining certain asset levels in certain types of brokerage accounts, and on annual trade volumes. We address this conflict of interest by monitoring trade execution and through account reviews as described in (Item 13) Review of Accounts below. NFS provides financial assistance to First Horizon Advisors, Inc. in the form of credits to First Horizon Advisors, Inc. on the fees and charges billed to First Horizon Advisors, Inc. under its clearing agreement with NFS. An account custodied at NFS may be invested in mutual funds or ETFs which pay shareholder servicing, 12b-1 fees or administrative services fees to the Advisor in connection with investment of the Account in shares of the mutual funds or ETFs (“Mutual Fund Fees”). The Advisor has AMH/45241.v2 18  instructed NFS to rebate the Mutual Fund Fees back into the Accounts that generated the Mutual Fund Fees. IRA Accounts are charged an annual IRA maintenance fee by NFS. NFS has agreed to pay a portion of such maintenance fee to First Horizon Advisors, Inc. NFS has also agreed to pay First Horizon Advisors, Inc. a portion of the account transfer fees (ACAT) charged to an Account. If an Account custodied at NFS incurs margin interest, a portion of the margin interest charged to the Account is paid to First Horizon Advisors, Inc. The expense ratio of the mutual fund share class is considered when selecting a mutual fund for your account. Not all share classes of a mutual fund are available to an account. Share classes, share class expenses, and eligibility for investment in a share class change frequently. We periodically review the mutual fund share classes to determine if a share class with a lower expense ratio is available for our accounts. If so, when reasonably practical, we will exchange the existing share class in an account for a share class with a lower expense ratio. When a client utilizes one or more separate account managers, the Advisor will recommend that the client use the First Horizon Bank Trust Division as custodian. The relationship between the First Horizon Bank Trust Division and the Advisor is disclosed to the client. In the event of a trade error on the part of the Advisor, the Advisor will correct the error by executing the appropriate trades for the client’s account and for the Advisor’s account. The Advisor will reimburse the client’s account for any market loss incurred as a result of the error. In the event the trades executed for the Advisor’s account to correct an error results in a gain for the Advisor’s account, the Advisor will retain such gain. REVIEW OF ACCOUNTS (Item 13) Account Reviews. For Other Advisory Services, the Advisor has designated certain employees as “Advisory Account Reviewers.” Each account is reviewed by an Advisory Account Reviewer prior to account opening to confirm that recommendations for the account are consistent with the client’s investment objectives and risk tolerance. At least annually, the IP meets with his/her clients to determine if there have been any changes in the client’s investment objectives which require a change in the client’s portfolio. For CRP Services, mutual funds and managers are reviewed with the client in accordance with the consulting agreement. For Financial Planning, the Advisor reviews a sample of financial plans where a client has implemented plan recommendations through the Advisor or its affiliates. All FAs who provide financial planning are CFP® professionals. Reports. For CRP Services accounts, written reports will be provided as described in the consulting agreement with the client. For Other Investment Advisory Services, all clients receive a written quarterly report from the account custodian with a breakdown of investments held, gains, losses, and current market value. AMH/45241.v2 19  Clients will receive a quarterly performance report from the Advisor if such report is described in the investment management services agreement with the client. Financial planning does not involve custody of assets. You will receive a copy of your plan in written or electronic form. CLIENT REFERRALS AND OTHER COMPENSATION (Item 14) Please see (Item 5) above Compensation, Financial Benefits and Conflicts of Interest – First Horizon Bank for information concerning compensation Bank employees can receive in connection with referring clients to the Advisor and/or obtaining investment management services from the Advisor. Please see (Item 10) Other Financial Industry Activities and Affiliations above for more information concerning referral fees paid to IPs by First Horizon Bank and First Horizon Bank Trust Division. CUSTODY (Item 15) The Bank provides custody services to clients through its Trust Division. Under the SEC rules, we are deemed to have custody of accounts held by the First Horizon Bank Trust Division. All accounts custodied by the First Horizon Bank Trust Division will receive account statements, at least quarterly, from the First Horizon Bank Trust Division. Clients should carefully review these account statements. The Advisor does not provide a separate statement for these accounts. The Advisor is deemed to have custody over a client’s assets when it is authorized to directly debit a client’s account for payment of the Advisor’s fees. The Advisor has custody of client accounts if the client has executed a standing letter of authorization that permits the Advisor to make distributions to third-parties from the client’s account. Financial planning services do not involve custody of client assets. INVESTMENT DISCRETION (Item 16) The Advisor’s authority to execute transactions for a client account without the client’s prior approval or to hire or terminate an investment manager without the client’s prior approval will be obtained in writing from the client. This authority is described in the investment management agreement between the Advisor and the client. Financial planning services do not include the authority to execute transactions for a client account. VOTING CLIENT SECURITIES (Item 17) Your investment advisory agreement will state whether or not we will vote proxies related to the securities holdings in your account. The Advisor has adopted proxy voting guidelines and procedures. These guidelines and procedures are designed to ensure that proxies are voted in a manner that maximizes shareholder value and avoids AMH/45241.v2 20  conflict of interest between us and our clients. The Advisor has contracted with Institutional Shareholder Services, Inc. (“ISS”) to provide policy recommendations, research, vote proxies, and assist with the administration and record keeping related to proxy voting. Using these guidelines, ISS will make recommendations on how to vote proxies. Generally, the Advisor will vote in accordance with ISS’ voting recommendations. However, we reserve the right to vote in a different manner if we believe it is in the best interest of our clients to do so. Where a conflict of interest exists, we will contact the client, disclose the conflict, and obtain the client’s consent or direction to vote the proxy. Although we do not make recommendations concerning FHC securities, a conflict of interest arises if a proxy vote involves a transaction with FHC or its affiliates. Clients can contact us at 901-818-6065 or 1-800-300-0987 to obtain a copy of our proxy voting guidelines or for more information about voting proxies. First Horizon Bank Trust Division votes proxies for securities held in the Agency Accounts. FINANCIAL INFORMATION (Item 18) Registered investment advisers are required in this item to provide clients with certain financial information or disclosures about their financial condition. The Advisor has no financial commitments that impair its ability to meet contractual and fiduciary obligations to clients, and has not been the subject of a bankruptcy proceeding. AMH/45241.v2 21 

FIRST HORIZON ADVISORS, INC. PART 2A APPENDIX 1 FORM ADV MANAGED ACCOUNT SOLUTIONS WRAP FEE PROGRAM BROCHURE 4990 Poplar Ave. 3rd Floor Memphis, TN 38117 March 2025 www.firsthorizon.com This Wrap Fee Program Brochure provides information about qualifications and business practices of First Horizon Advisors, Inc. If you have any questions about the contents of this brochure, please contact us at 901-818-6065 or 1-800-300-0987. 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. First Horizon Advisors, Inc. is registered with the SEC as a registered investment adviser. Additional information about First Horizon Advisors, Inc. is also available on the SEC website at www.adviserinfo.sec.gov. References to First Horizon Advisors, Inc. as a “registered investment adviser” or as being “registered” does not imply a certain level of skill or training. AMH/45242.v2  MATERIAL CHANGES (Item 2) At least annually, we will provide you a summary of the material changes made to our Wrap Fee Brochure or a complete copy of the updated Wrap Fee Brochure. At any time, you can request a complete copy of the brochure by contacting us at 901-818-6065 or 1-800-300-0987. This section describes material changes made to the Wrap Fee Brochure since the last update of this brochure in October 2024. ( Item 4) Services, Fees and Compensation- Financial Benefits and Conflicts of Interest- Investment Professional Compensation has been updated to add the following as an incentive that may be paid to an FA or IAR when employed by the Advisor: loan along with an incentive plan to provide for repayment of the loan − ( Item 4) Services, Fees and Compensation- Financial Benefits and Conflicts of Interest- First Horizon Bank has been revised to add the following: Certain Retail Bank employees participate in a bonus program which is based upon revenue generated from the products or services, including investment advisory services obtained by Bank clients assigned to the employee’s branch location. These employees are eligible to receive a payment of a fixed amount which may increase or decrease based upon the percentage of the target revenue achieved. AMH/45242.v2 2  (Item 3) TABLE OF CONTENTS Page Number (Item 1) Cover Page 1 (Item 2) Material Changes 2 (Item 3) Table of Contents 3 (Item 4) Services, Fees & Compensation 5 5 • Description of Services – General 5 • Description of Services – Separately Managed Accounts 6 • Description of Services – Advisor Directed Unified Managed Accounts 6 • Description of Services – First Horizon Advisors Model Accounts 7 • Description of Services – Advisor Model Managed Accounts 8 • Description of Services – Fund Strategist Portfolio Accounts 8 • Description of Services – WealthBuilder Accounts 9 • Maximum Fee Schedules – SMAs; WealthBuilder Accounts; First Horizon Advisors Model Accounts; AMMAs; FSPs, and ADUMAs 9 • Program Fee Calculation and Payment 10 • Charges Excluded From the Program Fee 11 • Compensation, Financial Benefits and Conflicts of Interest (Item 5) Account Requirements and Types of Clients 14 14 • Account Requirements 15 • Types of Clients (Item 6) Portfolio Manager Selections and Evaluation 15 15 • Sub-Manager Selection and Evaluation 15 • Advisory Business 17 • Performance Based Fees AMH/45242.v2 3  Page Number 17 • Methods of Analysis, Investment Strategies and Risk of Loss 20 • Voting Client Securities (Item 7) Client Information Provided to Portfolio Managers 21 (Item 8) Client Contact with Portfolio Managers 21 (Item 9) Additional Information 21 21 • Disciplinary Information 23 • Other Financial Industry Activities or Affiliations 24 • Code of Ethics Interest in Client Transactions 24 • 24 • Trade Execution 26 • Review of Accounts 26 • Reports 26 • Client Referrals 26 • Financial Information AMH/45242.v2 4  SERVICES, FEES & COMPENSATION (Item 4) Description of Services – General. The Managed Accounts Solutions Program (“MAS Program” or the “Program”) offers the following investment management account options: • Separately Managed Accounts (“SMA”) • Advisor Directed Unified Managed Accounts (“ADUMA”) • First Horizon Advisor Model Accounts • Advisor Model Managed Accounts (“AMMA”), (Discretionary and Non-Discretionary) • Fund Strategist Portfolio Accounts (“FSP Accounts” or “FSPs”), and • WealthBuilder Model Accounts (“WealthBuilder Accounts”). First Horizon Advisors, Inc. (the “Advisor”, “we”, “our” or “us”) is the sponsor of the Program. The Advisor and Envestnet Asset Management, Inc. (“Envestnet”) provide certain investment advisory services and administrative services for assets held in the Accounts. Envestnet is not affiliated with the Advisor. For the SMAs and ADUMAs, the Advisor and Envestnet provide discretionary advisory services. For First Horizon Advisors Model Accounts and AMMAs – Discretionary, the Advisor provides discretionary advisory services and Envestnet provides administrative services, only. For AMMAs – Non-Discretionary, the Advisor provides non-discretionary advisory services and Envestnet provides administrative services only. For WealthBuilder Accounts and FSPs, investment managers provide their model portfolios to Envestnet under a separate licensing agreement. Envestnet will execute trades for the Account in accordance with the applicable model portfolio and changes to the model portfolio by the investment manager, from time to time. The Program is offered through our Financial Advisors, Investment Advisor Representatives, and members of our Investment Services team (collectively, Investment Professionals (“IPS”) and each an “Investment Professional” (“IP”). Description of Services – Separately Managed Accounts. Prior to opening an SMA, your IP will assist you in completing an investment profile to provide us information concerning your investment objectives, financial goals, and risk tolerance. Based on this information, your IP will provide you a Statement of Investment Selection (“SIS”). The SIS includes a recommended asset allocation and investment recommendations for each asset category. The SIS may refer to “SMA” as the Envestnet “Separate Accounts Program”. The SIS is prepared by your IP using the Envestnet platform software applications. Among the factors considered in designing the strategy are historical rates of risk and return for various asset classes, correlation across asset classes, and risk premium. Your IP will recommend independent asset managers (“Sub-Managers”) who will create a separate portfolio of individual managed securities to correspond to proposed asset classes and styles for the Account. Subject to the limitations described in your SIS and other reasonable restrictions you may place on the SMA investments, Envestnet has discretion to hire the selected Sub-Managers for the Account. The Sub-Managers have full authority to supervise and direct investment of assets in the SMAs without your prior approval. This investment authority includes purchases and sales of individual securities, options and alternative investments. You can modify the information in your investment profile by contacting your IP at any time. Changes in your investment profile may AMH/45242.v2 5  result in changes to your SIS. For certain Sub-Managers, Envestnet has entered into a licensing agreement with the Sub-Manager. In these cases, Envestnet provides administrative and/or trading services in accordance with the instructions of the Sub-Manager. Envestnet has the authority at any time without your prior approval to terminate Sub- Managers and replace Sub-Managers to manage the SMA assets. We also have the authority to terminate a Sub-Manager and replace that Sub-Manager with another Sub-Manager available under the Program without your prior approval. The minimum account size for an SMA is $100,000. However, some Sub-Managers require a minimum account value that is greater than $100,000. Description of Services – Advisor Directed Unified Managed Accounts. Prior to opening an ADUMA, your FA or IAR will assist you in completing an investment profile. The investment profile provides information about your investment objectives, financial goals and risk tolerance. Based on this information, your FA or IAR provides you a Statement of Investment Selection (“SIS”). The SIS recommends an asset allocation and investments for each asset category. The SIS is prepared by your FA or IAR by using the Envestnet platform software application. The factors considered in designing the strategy include the historical rates of risk and return for various asset classes, correlation across asset classes, and certain risk premium measures. the asset manager’s model portfolio and Subject to the limitations described in your SIS, your FA or IAR will select individual asset managers and/or individual investments for each asset category. For assets assigned to certain asset managers, Envestnet uses investment recommendations to manage that portion of the Account assets. Your FA or IAR may also select mutual funds, ETFs, and alternative investments. Envestnet provides overlay management services for the ADUMA. You directly own the individual securities in the ADUMA. We have the authority to buy, sell and exchange mutual fund shares and ETFs in the ADUMA without your prior approval subject to the limitations and objectives in your SIS. The minimum account size for an ADUMA is $150,000. The Advisor may, in its sole discretion, waive the account minimum and accept the account with a lower value. Description of Services – First Horizon Advisors Model Accounts. Prior to opening a First Horizon Advisors Model Account, your IP will assist you in completing an investment profile. The investment profile provides information concerning your investment objectives, financial goals and risk tolerance. Based on this information, your IP will provide a Statement of Investment Selection (“SIS”). The SIS is prepared by your IP using the Envestnet platform software application. Among the factors considered in determining an appropriate strategy are capital market assumptions concerning the rates of risk and return for various asset classes, correlation across asset classes, and risk premium measures. The SIS will recommend using one or more model portfolios (the “First Horizon Advisors Model Portfolios”). Each First Horizon Advisors Model Portfolio has a designated risk based investment strategy. Except as described below, the SIS will refer to the “First Horizon Advisors Model Account” option as a “Fund Strategist Portfolio Account” managed by First Horizon Advisors, Inc. Investments for a First Horizon Advisors Model Portfolio include no load or load waived mutual funds, ETFs, and alternative investments. The Advisor’s Investment Committee (the “IC”) will review all First Horizon Advisors Model Portfolios at least semi-annually, including a review of performance vs. an appropriate benchmark. In constructing First Horizon Advisors Model Portfolios, the Advisor evaluates mutual fund and ETF holdings utilizing third-party screening AMH/45242.v2 6  tools. The factors considered in evaluating mutual funds and ETFs include investment performance vs. peers, stated benchmarks, a series of risk and reward measures, style consistency, fees and/or tracking error. The following First Horizon Advisors Model Portfolios are available which utilize individual stocks: Each of these portfolios is referred to in the SIS as a “Separate Account” managed by First First Horizon Advisors Large Cap Core Portfolio First Horizon Advisors Dividend Portfolio • First Horizon Advisors Growth Focused Portfolio • First Horizon Advisors Equity Income Focused Portfolio • First Horizon Advisors Total Return Focused Portfolio • • Horizon Advisors, Inc. From time to time the Advisor may reduce or waive the minimum needed to open an Account utilizing First Horizon Advisors Model Portfolios. The Advisor may place conditions on a waiver or reduction of the initial market value of the Account assets. Under the First Horizon Advisors Model Accounts option, the Advisor also makes available First Horizon Factor Models. The SIS refers to this First Horizon Advisors Model Account as a “Fund Strategist Portfolio Account” utilizing a “First Horizon Advisors Factor Model”. For more information concerning the IC, please see (Item 6) Portfolio Manager Selection and Evaluation. Description of Services – Advisor Model Managed Accounts. Prior to opening an AMMA, a Financial Advisor (“FA”) or an Investment Advisor Representative (IAR) will assist you in completing an investment profile. The investment profile provides information concerning your investment objectives, financial goals and risk tolerance. Based on this information, your FA or IAR will provide you a Statement of Investment Selection (“SIS”). The SIS includes a recommended asset allocation and recommended investments as determined by your risk tolerance profile. The SIS is prepared by your FA or IAR using the Envestnet platform software. Among the factors considered in designing an appropriate strategy are capital market assumptions concerning the rates of return and risk for various asset classes and correlation across asset classes. Assets held outside of the Program Account may also be considered when developing the strategy for an AMMA. The SIS usually identifies this Program option as an “Advisor Model.” In some cases, your FA or IAR may use another name to identify the AMMA. In that case, the FA or IAR will disclose to you the name selected for this Program option. When opening an AMMA, you may grant the FA or IAR the authority to invest, reinvest, and otherwise deal with assets in the AMMA without obtaining your prior approval. In this case, your Account will be designated AMMA – Discretionary. In the event you desire that your FA or IAR invest, reinvest, and otherwise deal with assets in your Account only upon your prior approval AMH/45242.v2 7  of such actions, your Account will be designated AMMA – Non-Discretionary. All references to “AMMAs” in this Brochure shall mean collectively, AMMAs – Discretionary and AMMAs – Non-Discretionary. Investment options the FA or IAR may recommend include mutual funds, ETFs, and individual equities. Individual bonds, preferred stocks, real estate investment trusts and structured notes, and alternative investments may also be used. The IC is responsible for approving the AMMA – Discretionary investment programs. The AMMA – Discretionary program option is available from a limited number of FAs and IARs who have met minimum qualifications set by the IC. The minimum value of assets to open an AMMA is $100,000. AMMAs are different from First Horizon Advisors Model Accounts in that your FA or IAR will select the investments for your AMMA, but a member of the IC will select the investments for First Horizon Advisors Model Accounts. All investments purchased for an AMMA or for a First Horizon Advisors Model Account will be on the working list of investments maintained by the IC. First Horizon Advisor Model Accounts and AMMAs are constructed using the same risk-based models. The fees and performance of an AMMA will be different from the fees and performance of a First Horizon Advisors Model Account using the same investment strategy. Description of Services – Fund Strategist Portfolio Accounts. Prior to opening a Fund Strategist Portfolio Account, your IP will assist you in completing an investment profile. The investment profile provides information concerning your investment objectives, financial goals and risk tolerance. Based on this information, your IP will provide a Statement of Investment Selection (“SIS”). The SIS is prepared by your IP using the Envestnet platform software application. Among the factors considered in determining an appropriate strategy are capital market assumptions concerning the rates of risk and return for various asset classes and risk premium measures. The SIS will recommend using a model portfolio (“Model Portfolio”) of a third party manager (“Model Provider”). Envestnet will execute trades for your Account in accordance with the applicable Model Portfolio and changes to the Model Portfolio from time to time. Investments for the FSP Account are mutual funds or exchange traded funds (“ETFs”). The minimum account size for an FSP Account is $100,000. The Advisor may, in its discretion, waive the account minimum and accept the account with a lower value. Description of Services – WealthBuilder Accounts. Prior to opening a WealthBuilder Account, your IP will assist you in completing an investment profile to provide us information concerning your investment objectives, financial goals, and risk tolerance. Based upon this information, your IP will provide you a Statement of Investment Selection (“SIS”). The SIS is prepared by your IP using the Envestnet platform software application. The SIS will recommend using one or more Model Portfolios constructed by Model Providers. Envestnet provides overlay management services for the WealthBuilder Accounts by implementing trade orders and updating and rebalancing the investments in the WealthBuilder Accounts in accordance with changes made to the Model Portfolios by the Model Providers. Depending upon the Model Portfolio selected, the WealthBuilder Account will utilize ETFs, no load or load waived mutual funds. The SIS may refer to these accounts as “WealthBuilder Accounts” as “Low Minimum Fund Strategist Solutions Program”. The minimum market value of assets required to open a WealthBuilder Account is $50,000. The Advisor may, at its sole discretion, accept an account with a lower value depending on the circumstances. AMH/45242.v2 8  Maximum Fee Schedules – SMAs; WealthBuilder Accounts; First Horizon Advisors Model Accounts; AMMAs; FSPs; and, ADUMAs. The Program Fee listed below is the maximum Program Fee which may be charged for the Account options. The Program Fee is negotiable, and the fee charged to your Account will be described in the SIS. The Program Fee is a combined fee for investment advice, brokerage, clearance, settlement, and custody services. You will also be charged for or incur fees and expenses not covered by the Program Fee. For more information about these charges and fees please see “Charges Excluded From Program Fee” below. SMAs First $500,000 Next $500,000 Next $1,000,000 Next $3,000,000 Over $5,000,000 Annual Rate 2.00% 1.90% 1.75% 1.50% 1.25% Annual Rate WealthBuilder Accounts Mutual Fund & ETF Solutions Accounts First $100,000 Next $400,000 Next $500,000 Over $1,000,000 2.00% 1.90% 1.75% 1.50% Annual Rate First Horizon Advisors Model Accounts; AMMAs & FSPs First $500,000 Next $500,000 Next $1,000,000 Next $3,000,000 Over $5,000,000 2.00% 1.75% 1.50% 1.50% 1.50% ADUMAs First $500,000 Next $500,000 Next $1,000,000 Over $3,000,000 Annual Rate 2.00% 1.90% 1.75% 1.50% Program Fee Calculation and Payment. The Program Fee is calculated by applying the applicable annual fee schedule in the SIS to the asset value of the Account assets invested in a Program option. Any assets held in an Account and not invested in a Program option will be excluded from the calculation of the Program Fee and from the minimum value of assets required to open an Account. The value of the Account assets is determined quarterly on an Account by AMH/45242.v2 9  Account basis and not in the aggregate. The initial Program Fee will equal (on an annualized basis) the percentage (as set forth in the fee schedule in the SIS) of the value of the Program Assets in the Account for the applicable Program option. The Advisor or Envestnet will instruct the Account custodian, National Financial Services, LLC (“NFS”), to deduct the Program Fees from the Account(s). The Program Fee is debited from each Account on a quarterly basis in advance. You are responsible for verifying the accuracy of the Program Fee calculation. Envestnet receives a portion of the Program Fee for the investment management and/or administrative services it provides to the Accounts. Fees due Sub-Managers and any third-party service providers retained by Envestnet in connection with the Program are paid by Envestnet. The amount of the Program Fee that we receive for providing investment advisory and/or management services to an Account varies depending upon the type of Account, the number of Sub-Managers used in an SMA, the number of model portfolios utilized by an ADUMA, and in some cases the trading activity in the Account. The initial Program Fee is calculated and debited on the 10th day of the month (or the next business day if the 10th is a non-business day) after initial assets are placed in the Account. The initial Program Fee is the Program Fee for the first calendar quarter (or part thereof) in which you open an Account. The initial Program Fee for any partial calendar quarter is pro-rated based on the number of calendar days in the partial quarter. Thereafter, the Program Fee is calculated at the beginning of each calendar quarter based on the value of Account assets on the last business day of the prior calendar quarter. However, if an Account is opened in the last month of a calendar quarter, the Program Fee is calculated and debited for the remaining period in the calendar quarter plus the next calendar quarter on the 10th day (or the next business day if the 10th is a non-business day) after initial assets are placed in the Account. For example, if an Account was opened on 6/26/24, Program Fees would be debited on 7/10/24 for the periods (6/26/24 to 6/30/24 and (7/01/24 to 9/30/24). If you invest $10,000 or more in any Account after the inception of a calendar quarter, the Program Fee for that quarter is recalculated and pro-rated as of the day of the additional investment. Envestnet determines the value of the Account assets for purposes of calculating the Program Fee. If the Account is terminated and all Program Assets are withdrawn from the Account prior to the end of a quarter, a pro rata portion of the Program Fee will be credited to your Account. Charges Excluded From the Program Fee. The Program Fee does not cover certain charges associated with securities transactions in the Accounts, including: • dealer markups, markdowns or spreads charged on transactions in over-the-counter securities; • costs relating to trading in certain foreign securities; • the internal charges and fees that are imposed by any collective investment vehicles (“Collective Investment Vehicles”), such as mutual funds and closed-end funds, unit investment trusts, exchange-traded funds or real estate investment trusts (such as fund operating expenses, management fees, redemption fees, 12b-1 fees and other fees and expenses). Further information regarding charges and fees assessed on Collective Investment Vehicles are described in the appropriate prospectus or offering document or other regulatory filings; AMH/45242.v2 10  • brokerage commissions or other charges imposed by broker-dealers or entities other than • the custodian if and when trades are cleared by another broker-dealer; the charge to carry tax lot information on transferred mutual funds or other investment vehicles, postage and handling charges, returned check charges, transfer taxes; stock exchange fees or other fees mandated by law; and • any brokerage commissions or other charges, including contingent deferred sales charges (“CDSC”), imposed upon the liquidation of “in-kind assets” that are transferred into the Account. • margin interest incurred as a result of the liquidation of margin securities transferred “in- kind” into the Account. You should be aware that if you transfer in-kind assets into an Account, Envestnet or the Advisor will liquidate such assets immediately or at a future point in time and you may incur a brokerage commission or other charge, including a CDSC. You also may be subject to taxes when these assets are liquidated. You should consult with your tax advisor before transferring in-kind assets into an Account. The Program Fee does not include certain fees that are charged by the custodian. You will be charged for specific account services you select to use, such as account transfer fees (ACAT), electronic fund and wire transfer charges, and for other optional services. If you incur any of the following charges or fees, the Advisor will retain a portion of the fees charged to your account for the services: ACAT; margin interest; bounced check; stop payment; transfer and ship (Direct Registration System Eligible) and wire fees (except wire fees charged to IRAs). The Program Fee does not cover certain non-brokerage-related fees such as individual retirement account (“IRA”) trustee or custodian fees and tax-qualified retirement plan account fees and any annual or termination fees for retirement accounts (such as IRAs). Some mutual funds assess redemption fees to investors upon the short-term sale of its funds. Depending on the particular mutual fund, you may incur a redemption fee when a fund is sold for rebalancing purposes or if the portfolio manager determines that it is in your overall interest to divest from certain fund holdings prior to the expiration of the minimum holding period. Please see the prospectus for the specific mutual fund for detailed information regarding such fees. You will also incur transaction charges or commissions for transactions not processed through First Horizon Advisors, Inc. Please see (Item 9) Additional Information - Trade Execution below. Compensation, Financial Benefits, and Conflicts of Interest. Advisor Compensation. The Firm receives a portion of the Program Fee as compensation for investment advisory services and administrative services we provide to the Program. The amount of the Program Fee we receive depends upon the type of Account, number of Sub- Managers used in an SMA, the number of Model Portfolios used in an ADUMA; and, in some cases trading activity in the Account. The Program Fee and the other fees and charges you incur may be more or less than the charges and fees you would pay if you separately purchased the advisory services, the brokerage services and the custody services. The cost of an MAS Program Account compared to the cost of an alternate investment program varies based upon a number of AMH/45242.v2 11  factors including account size, trading activity, types of securities included, and the variety of services provided. Investment Professional Compensation. An FA or IAR’s compensation depends upon the products that the IP sells. Our compensation plans are subject to change at any time. Compensation for an FA or IAR is based upon total fees, commissions and other revenue paid to the Advisor for products and services the FA or IAR sells. This is referred to as the “production”. The FA or IAR is paid a percentage of their total production each month. This is referred to as the “pay-out rate”. An FA or IAR will receive either a fixed pay-out rate or a pay- out rate that will increase as the FA’s or IAR’s total production increases over the compensation period. FAs or IARs who work on a team will have a fixed pay-out rate. Members of the team determine the amount of the total pay-out each team member will receive. An FA or an IAR may also receive a fixed pay-out rate if a fixed pay-out rate is provided for in the FA’s or IAR’s individual incentive plan. An FA or IAR receives a minimum guaranteed draw. The FA or IAR receives a pay-out as described above only if the pay-out exceeds the monthly draw. The Brochure Supplement for your FA or IAR contains additional information concerning the compensation your FA or IAR receives. Certain costs that the firm incurs to support an FA, an FA team, or an IAR are deducted from the total production. However, these charges will be waived if the FA, FA team; or, IAR meets a specified production level. On occasion, the Advisor provides incentive compensation to an FA or IAR when employed by the Advisor. These incentives can include one or more of the following: − forgivable draw which allows the FA or IAR to receive a pay-out even if the pay- out does not exceed the draw fixed pay-out percentage of production for a set time period loan along with an incentive plan to provide for repayment of the loan − one-time upfront payment − − Employees of the Advisor who supervise FAs and IARs are eligible to receive quarterly and annual bonuses. Quarterly bonuses are based upon a net-profit margin calculation which includes the revenue and expenses associated with the offer and sale of wealth management products and services, including revenue received from the Program Accounts. The annual bonus is based upon revenue associated with the offer and sale of wealth management products and services, including revenue received from the Program Accounts, as well as other factors. First Horizon Bank. The Advisor has entered into a Solicitation Agreement with First Horizon Bank in order to permit Bank employees to refer clients to the Advisor in exchange for compensation. If a licensed Bank employee refers a client to the Advisor and the client opens an investment management account, the Advisor will pay the Bank employee a portion of the advisory fees received from the account. Client Relationship Managers, including Private Client Relationship Managers, participate in a bonus program. Payments under the program are based upon multiple factors including revenue growth associated with products and services obtained by the Relationship Manager’s clients, including investment management services from the Advisor. Certain Retail Bank employees participate in a bonus program which is based upon revenue AMH/45242.v2 12  generated from the products or services, including investment advisory services obtained by Bank clients assigned to the employee’s branch location. These employees are eligible to receive a payment of a fixed amount which may increase or decrease based upon the percentage of the target revenue achieved. These arrangements provide an incentive for Bank employees to refer their clients to the Advisor to obtain investment management services. The Advisor addresses this conflict of interest through this disclosure and the account reviews as described in (Item 9) below Additional Information – Review of Accounts. Investment Services team members receive a salary and bonus. The bonus is not based upon the products sold to clients. Diamond Circle. Each year, we hold a conference that recognizes our highest producing IPs. The conference includes training sessions, an awards banquet, and travel and related expenses for attendees. We establish the criteria for attendance, including the number of invitees and the required production level for the awards. The conference is not a reward for the sale of any specific product or service. For more information concerning compensation of FAs and IARs related to Trust Division Referrals and First Horizon Bank referrals, please see (Item 9) Additional Information – Other Industry Activities or Affiliations – First Horizon Bank Trust Division and First Horizon Bank. Conflicts of Interest. Your FA or IAR receives compensation from the Advisor when you establish a Program Account and while your Program Account is open. The amount of this compensation is based upon the type of Program Account selected and the Program Fee charged. Therefore, your FA or IAR takes into consideration this compensation arrangement when a Program Fee is negotiated, and a Program option is recommended. Your IP separately negotiates Program Fees for each MAS Program Account that is opened. Therefore, negotiated Program Fees for the same Account type will vary by client and by IP. Advisor addresses this conflict of interest through this disclosure and the Account reviews as described in (Item 9) Additional Information - Review of Accounts. Brokerage and Advisory Accounts. Most of our IPs provide both brokerage services and investment advisory services. Your IP will orally disclose whether they provide both services or just investment advisory services. There are important differences in the services you receive and the fees you will pay depending upon which type of account you open. When recommending the type of account and services to you, your IP will consider your trading activity, desire for account monitoring, information and reporting requirements, and other information. When you open a brokerage account, we will receive compensation based upon the product we sell you. This is called “transaction based compensation”. When you open an advisory account such as a Program Account, you pay an ongoing fee based upon the value of the account. The fee is paid quarterly. Due to the difference in how we are paid for these services and whether your IP is an IAR or an FA, your IP has a financial incentive to recommend one type of account over the other type of account. An advisory account, such as a Program Account, is a fee based account which results in ongoing quarterly revenue credited to an FA’s or IAR’s production. Brokerage accounts result in revenue credited to the FA’s production at the time the transaction is executed. Some brokerage products also pay ongoing fees known as trail fees, which will be credited to the FA’s production on a monthly or quarterly basis. An IAR does not offer brokerage services or insurance products. Therefore, your IAR has an incentive to recommend the MAS Program rather than refer you to an FA or third-party to consider other products or services that may meet your financial needs. The AMH/45242.v2 13  Advisor addresses this conflict of interest through this disclosure and the Account reviews as described in (Item 9) Additional Information - Review of Accounts. Sponsor Payments. Custodians, mutual fund companies, investment advisors, and other service providers or product providers that participate in the MAS Program or otherwise provide products or services to First Horizon Advisors, Inc. (collectively, “Sponsors”) will provide certain financial benefits to the Advisor and/or an IP. Sponsors will provide educational training or marketing support to the Advisor and its IPs. Sponsors will contribute to the cost of conferences or meetings attended by some or all of the IPs. Such conferences and meetings include educational and training sessions as well as promotion of the MAS Program and other services provided by the Advisor. Some Sponsors will bear the expense for an IP to attend due diligence trips at the Sponsors’ offices or other locations. All or a portion of the costs of certain client events will be paid for by a Sponsor. Products and services provided by the Sponsors help the Advisor and its IPs to manage and administer client accounts. The Advisor and the IPs will use such products and services for MAS Accounts as well as other types of accounts and products offered by the Advisor. Sponsors pay for occasional meals and entertainment for and provide promotional items to IPs. These benefits build relationships with IPs which could lead to sales of the Sponsor’s products or services to you. We address this conflict of interest through this disclosure and the Account reviews as described in (Item 9) Additional Information - Review of Accounts. See (Item 9) Additional Information – Trade Execution for information concerning financial benefits related to our clearing arrangement with National Financial Services, LLC (NFS). (Item 5) ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Requirements. The minimum market value of assets required to open an Account is as follows: Program Option First Horizon Advisors Large Cap Portfolios ADUMAs and First Horizon Advisors Total Return Focused Portfolio Minimum Opening Account Value* $175,000 $150,000 $100,000 First Horizon Advisors Model Portfolios – Dividend: Growth Focused; Equity Income Focused; and Stable Allocation WealthBuilder Accounts $50,000 $20,000 First Horizon Advisors Model Portfolios – ETFs (except Stable Allocation Portfolios) All Other Accounts $100,000 * The minimum opening account value is subject to waiver or reduction from time to time under certain conditions determined by Advisor. The Sub-Managers utilized in the SMA program option may impose a minimum market value of assets to obtain their Sub-Manager services. Such minimums may be greater than $100,000. AMH/45242.v2 14  Types of Clients. The Accounts are available to individuals, high net worth individuals, trusts, estates, charitable organizations and corporations or other business entities. (Item 6) PORTFOLIO MANAGER SELECTIONS AND EVALUATION Sub-Manager Selection and Evaluation IPs select Sub-Managers from an approved list of Sub-Managers maintained by Envestnet. IPs may also select Sub-Managers from a list of Sub-Managers which are reviewed by Envestnet and approved by the Advisor. Envestnet’s ADV Part 2 describes the process Envestnet uses to review and approve Sub- Managers. At least annually, the Advisor reviews Envestnet’s Sub-Manager selection process. This review includes a discussion with Envestnet to determine whether changes have been made in its process, and to address any changes in Envestnet’s management or operation. The Advisor does not review performance information of Sub-Managers to verify its accuracy or compliance with presentation standards. Performance information may not be calculated on a uniform and consistent basis by the Sub-Managers. At least annually, the Advisor reviews Sub-Managers which have been reviewed by Envestnet and which are available for SMAs. At least annually, the Advisor reviews Model Providers utilized by the Program. Generally, we will not change Sub-Managers unless the Sub-Manager is no longer approved by Envestnet or by us, or if there is a change in a client’s SIS. The timing of any such change may take into consideration specific Account concerns including tax sensitive issues. The Advisor is the portfolio manager for the First Horizon Advisor Model Accounts. IPs that provide AMMAs are responsible for investment selection for those Accounts. The IP has an incentive to recommend a First Horizon Advisor Model Account or an AMMA over other Program options. The Advisor manages this potential conflict by conducting initial and periodic reviews of the Account to determine that the Account option recommended to a client is suitable for the client’s investment needs and compatible with client’s risk tolerance and investment objectives. See (Item 9) Additional Information – Review of Accounts below. Advisory Business First Horizon Advisors, Inc. (formerly known as FTB Advisors, Inc.) is the successor-in- interest to First Tennessee Advisory Services, Inc. (“FTAS”). FTAS was organized in 2007 as a wholly owned subsidiary of First Tennessee Bank National Association, now known as First Horizon Bank (the “Bank”). The Bank is a wholly owned subsidiary of First Horizon Corporation (“FHC”), a financial services holding company. FHC is a publicly held company. On June 3, 2013, FTAS merged with and into its affiliated broker-dealer, First Tennessee Brokerage, Inc., and the combined entity was renamed FTB Advisors, Inc. In October 2019, FTB Advisors, Inc. changed its name to First Horizon Advisors, Inc. Investment management services provided by the Advisor include the following: AMH/45242.v2 15  • Managed Account Solutions Program (“MAS Program”) • Corporate Retirement Plan Services (“CRP Services”) • Other Investment Advisory Services • Financial planning services. CRP Services are provided to pension and savings plans including ERISA plans, government plans, and church plans. These services include: recommendations of investment options to be used for the plan • search and recommendations of investment managers for management of plan assets • • assistance in selection of plan service providers • ongoing review and reporting concerning selected investment managers, and investment options • employee education and plan enrollment services • benchmarking service to help determine plan costs vs. that of peer plans • assist in preparation of investment policy statement • search and recommendation of Qualified Default Investment Alternative (“QDIA”) The Advisor may also provide discretionary investment management services to a plan. The client enters into an agreement with the Advisor which describes the specific CRP Services to be provided to the client. These services are provided by certain FAs who are designated as Corporate Retirement Specialists. to understand Other Investment Advisory Services are provided on a discretionary or non-discretionary basis. Unless otherwise specified in the client agreement, these services involve providing ongoing investment advice. Services available include a review of the current investment portfolio and a consultation investment objectives and the current financial situation, recommendations for the client to consider. The client agreement identifies the specific services to be provided to a client. The Advisor develops an investment policy for the client or reviews an existing investment policy in order to recommend an appropriate asset allocation. Additional services include the selection of securities or managers, monitoring portfolio risk adjusted performance, progress towards or changes in objectives as well as providing performance reporting and economic updates. Where the Advisor recommends investment managers for an account, the arrangement will be provided through a sub-manager relationship with the Advisor. Under a sub- manager arrangement, the Advisor has authority to terminate a sub-manager and to replace the current sub-managers with another sub-manager. When we provide financial planning services, we gather the client’s financial data and identify the client’s long-term and short-term goals. An FA will utilize software which analyzes the data and assumptions provided. The process involves review of alternative courses and strategies to help meet the client’s financial goals. Once a strategy is selected, the FA will develop recommendations to address one or more of the following areas: investment portfolio allocations, life insurance coverage, disability coverage, education funding options, and estate planning. All clients undergo a profiling process to uncover specific information related to client risk tolerance, time horizon, need for income and effective tax rates. This information is used to suggest an appropriate risk-based model portfolio recommendation from a set of risk-based AMH/45242.v2 16  portfolios. During the profiling process, clients can impose restrictions on investing in certain types of securities or certain industries. AMMAs outline the specific needs of the client through use of an Investment Policy Statement (“IPS”) which contains information regarding the client’s investment objective, risk tolerance and any constraints imposed by the client. For First Horizon Advisors Model Portfolio Accounts, the Advisor will typically purchase and sell the same type of securities for all accounts using the same investment strategy, subject to reasonable restrictions imposed by the client. The Advisor provides continuous and regular supervisory or management services on both a discretionary and non-discretionary basis. Total assets managed on a discretionary basis as of December 31, 2024 were $10,066,599,359. Total assets managed on a non-discretionary basis were $3,550,935,412. as of December 31, 2024. Performance Based Fees The Advisor does not charge any performance based fees which are based on a share of capital gains or capital appreciation of the assets of a client. Methods of Analysis, Investment Strategies and Risk of Loss Investment Philosophy. Our investment philosophy is built around providing independent and objective needs based advice. We strive to diversify investments across asset classes, geographic regions, management styles and ownership structures. We use a top down approach designed around our client’s goals, objectives and risk tolerance. This approach considers relevant constraints as determined by the Investment Policy Statement or other account governing documents. These may include liquidity needs and timing of expected cash flow events as well as any constraints or legal considerations. Investment Strategies. The Advisor’s Investment Committee (“IC”) sets the broad investment policy based on the firm’s investment philosophy. Considerations include asset sub- class selection, creation and maintenance of a working list of investments, purchase and sale guidelines, and rebalancing guidelines. The Advisor has identified five factors that it believes to be a framework for market evolving trends. Those factors are the macroeconomic background, the trend of the market, liquidity conditions, market psychology, and fundamental valuations. Annually, the IC reviews capital market assumptions from industry sources. Based on this review, our strategic asset sub-class allocations and holdings may be modified. The Advisor does not advocate market timing. Investment Selection. To achieve proper diversification, the Advisor considers various investment categories including separate account managers, no-load mutual funds, individual large capitalization stocks, individual investment grade bonds, ETFs, as well as hybrid mutual funds, factor based funds, real assets, hedge products and other alternative investment products. The Advisor utilizes current economic, market and behavioral data as well as both internal and external sources for macro and micro-economic input, sector, industry, and individual security AMH/45242.v2 17  analysis. We also utilize third party software program(s) and research tools. We consider mutual funds, ETFs, separate account managers and their performance, style, and risk adjusted return measures. This data is used in the analysis of portfolios and their holdings. Initial Selection of Mutual Funds. The Advisor’s analysis includes both quantitative and qualitative criteria. We seek experienced managers with a competitive performance record, stable operations, and reasonable expenses. A second layer of evaluation includes performance against relevant benchmarks and peer groups including annualized, calendar year, and rolling returns. A style analysis is performed looking for a history of consistency in the fund’s investment philosophy and style purity. Risk adjusted return measures based on Modern Portfolio Theory are also reviewed for comparison to peers. Qualitative analysis may include firm history, financial stability, service standards, regulatory infractions, and manager turnover. Ongoing Oversight. As part of the regular due diligence, the Advisor will review many of the factors listed above to identify unfavorable trends over time. If an unfavorable trend has been identified, the IC will initiate an analysis to determine what actions, if any, need to be taken. The IC may consider opportunity costs and tax implications before initiating such changes. Fixed Income. The Advisor will select securities that meet the established quality, duration, and maturity criteria for the portfolio. The firm may use ETFs, mutual funds, or individual preferred securities and other diversifying securities meeting quality and liquidity requirements. The structure of the portfolio may be adjusted from time to time based on the evaluation of current and expected interest rates, economic conditions, monetary policy, fiscal policy, and inflation. The Advisor will monitor the credit quality of account holdings utilizing third party research and Envestnet system monitoring tools. If a security drops below an investment grade rating, the firm will assess the long term implications and take appropriate action as necessary. Equities. Equities are screened for initial selection and monitored for continued inclusion in portfolios using quantitative analysis tools provided by third-party research firms. These tools employ multifactor analysis, including variables such as profitability, valuation, operating efficiencies, relative risk, manipulation of reported earnings, relative analyst sentiment, and corporate governance. ETFs. An ETF is a fund that trades on an exchange, similar to stocks, and often seeks to track an index (e.g., S&P), commodity (e.g., oil, natural gas, gold, etc.), or a basket of assets like an index fund. As a result, ETFs often do not have the objective to outperform what they are tracking. However, some ETFs are actively managed and do not seek to track a certain index or basket of assets. ETFs may also have unique risks depending on their structure and underlying investments. ETFs may trade at a premium (above) or discount (below) to their net asset value (“NAV”), and may also be affected by the market fluctuations of their underlying investments. Risk of Loss. Investing in securities involves risk of loss of principal that a client should be prepared to bear. Cybersecurity Risk. Companies, markets, investment companies, including ETFs and mutual fund companies, and service providers, like us and NFS, use a significant amount of technologies in our/their day to day functions. As a result, these entities and those individuals who use these AMH/45242.v2 18  services, or have investments in these companies, are subject to a number of cybersecurity risks. Cybersecurity risks include, but are not limited to, compromised company, employee or client data, disruption of services, corruption or loss of data, inability to perform services (e.g., trading, valuation, issuance of reports, communications), and financial losses. Legislative and Regulatory Risk. Investments in your Account may be adversely affected by new laws or changes to existing laws or regulations. Changes to laws or regulations can impact the securities markets as a whole, specific industries, and individual issuers of securities. Asset Allocation and Diversification. Account performance depends upon allocation of assets among various asset classes and the selection of the underlying investments. There is a risk that the asset allocation, selection of asset classes and the underlying investments will cause the Account’s performance to lag relevant benchmarks or result in losses. While allocation to multiple asset classes can reduce risk, diversification cannot completely eliminate risk. Asset allocation and diversification do not guarantee a profit or protect against loss. Model Risk. Model Portfolios may be similar to other model portfolios used by other investment managers. In the event of a market disruption this may result in simultaneous trading in the market by investment managers which accelerates reduction in liquidity or repricing. This can also reduce the effectiveness of a model as more investment managers seek to capitalize on market inefficiencies Disruption in Financial Markets. Political instability, terrorism, widespread disease including pandemics and epidemics and natural or environmental disasters can be highly disruptive to the economies and the markets. Market disruptions may result in increased volatility, trading disruptions and other events which can negatively affect the value of investments held in your Account. Other risks may include: • Underperforming a benchmark • Reinvestment risk • Inflation risk • Not meeting financial objectives such as, retirement income and college financing • Liquidity risk • Political risk • Environmental risk • Corporate governance risk Investing in individual equities introduces idiosyncratic, or specific company risks to an investor’s portfolio. The portfolios are reviewed on an ongoing basis to determine if quantitative and/or qualitative changes warrant selling a stock from the portfolio holdings. Equity investments will experience volatility and market fluctuations. While diversification may mitigate these risks, extreme fluctuations can result in a loss of principal. In a volatile market, if a sale of securities is necessitated by an unforeseen event, a loss of principal can result. AMH/45242.v2 19  Fixed Income investments include a wide range of securities with an equally wide range of risk levels. Risk in fixed income securities comes from several sources including default risk, interest rate risk, inflation risk, currency risk and liquidity risk. Default Risk is the risk that the issuer of the bond does not make good on its obligation to pay periodic interest payments or principal at maturity. Obligations of investment grade corporations (and state and local governments) are not free from default risk, but that risk is viewed as being lower. Below investment grade bonds, i.e., junk bonds, are considered speculative in nature. Interest Rate Risk. Fixed Income securities also have interest rate risk; their market prices fluctuate up and down inversely with the prevailing interest rates. Notes and bonds purchased when interest rates are low can lose market value if interest rates rise prior to their maturity dates. As with stocks, if a sale of the bond is necessitated by an unforeseen event, a loss of principal can result. The longer the maturity of the bond held, the greater the interest rate risk, all else being equal. Inflation Risk. The inflation risk associated with bonds is twofold: the potential loss of purchasing power plus the potential for inflation to result in higher market rates of interest. As explained above, this causes the market price of a bond to decline. A portfolio manager can attempt to mitigate fixed income risks by using high credit quality bonds, and investing in bonds with short to intermediate terms. Alternative securities often carry liquidity risk as well as the risk of loss of principal. Liquidity risk is an inability to sell the security in a timely fashion should cash needs arise. Voting Client Securities Unless otherwise agreed to by the Advisor and Client, the Responsible Person identified below will vote proxies or take any and all actions on matters for which a security holder vote, consent or election or similar action is solicited by, or with respect to issuers of securities, beneficially held as part of the Program Assets in the Program Account. Program Account Responsible Person SMAs Platform Manager or Sub-Manager ADUMAs Platform Manager or Sub-Manager FSPs Platform Manager WealthBuilder Platform Manager First Horizon Advisors Model Advisor AMMAs Advisor AMH/45242.v2 20  Client reserves the right to revoke the authority of the Platform Manager or Advisor noted above by providing written notice to the Advisor. Client should review the Platform Manager’s or the Sub- Manager’s Form ADV Part 2A for a description of their proxy voting policies and procedures. The Advisor has adopted proxy voting guidelines and procedures. These guidelines and procedures are designed to ensure that proxies are voted in a manner that maximizes shareholder value and avoids conflict of interest between us and our clients. The Advisor has contracted with Institutional Shareholder Services, Inc. (“ISS”) to provide policy recommendations, research, vote proxies, and assist with the administration and record keeping related to proxy voting. Using these guidelines, ISS will make recommendations on how to vote proxies. Generally, the Advisor will vote in accordance with ISS’ voting recommendations. However, we reserve the right to vote in a different manner if we believe it is in the best interest of our clients to do so. Where a conflict of interest exists, we will contact the client, disclose the conflict, and obtain the client’s consent or direction to vote the proxy. Although we do not make recommendations concerning FHC securities, a conflict of interest arises if a proxy vote involves a transaction with FHC or its affiliates. Clients can contact us at 901-818-6065 or 1-800-300-0987 to obtain a copy of our proxy voting guidelines or for more information about voting proxies. (Item 7) CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Prior to opening an MAS Account, you will complete an investment profile which provides information concerning your investment objectives, financial goals, and risk tolerance. This information is used to develop your SIS. The SIS is available to Envestnet. You should notify your IP if there have been changes in your investment objectives or risk tolerance and you and your IP will determine if any changes need to be made to your SIS. Any changes to the SIS will be available to Envestnet. Your IP will initiate any changes for your Account as a result of a change in your SIS. (Item 8) CLIENT CONTACT WITH PORTFOLIO MANAGERS You should contact your IP in the event you have any questions concerning your Account. You should not contact Envestnet, the Model Provider, or the Sub-Manager(s) directly. (Item 9) ADDITIONAL INFORMATION Disciplinary Information The Advisor is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of the Advisor and its IPs and staff or the integrity of the Advisor’s management. UITs. The Financial Industry Regulatory Association (FINRA) alleged that the Advisor violated FINRA Rule 2010 by failing to apply sales charge discounts to certain eligible purchases of Unit Investment Trusts (“UITS”) from June 2010 to May 31, 2015. The allegations also included failure to establish, maintain and enforce a supervisory system and written supervisory procedures reasonably designed to ensure that customers received sales charge discounts on all eligible UIT purchases (NASD Rule 3010 and FINRA Rule 2010). AMH/45242.v2 21  The Advisor entered into an Acceptance, Waiver, and Consent with FINRA on December 3, 2015, without admitting or denying the allegations. The firm identified and reimbursed all customers for discounts which had not been applied plus interest on such amounts prior to entering into the consent, and paid a fine in the amount of $125,000 to FINRA. Variable Annuities. FINRA alleged that the Advisor failed to implement an adequate supervisory system and procedures designed to reasonably ensure suitability in its Multi-share Class Variable Annuity (“VAs”) sales, including L-share contracts. FINRA also alleged that during the relevant period, January 2013 – December 2014, the firm failed to establish, maintain, and enforce an adequate supervisory system and Written Supervisory Procedures (“WSPs”) related to the sale of Multi-share Class VAs, and that the firm failed to provide sufficient training to their registered representatives and principals on the sale and supervision of Multi-share Class VAs. FINRA alleged that the WSPs and training materials failed to sufficiently provide registered representatives and principals guidance or suitability considerations for sales of different VA share classes. FINRA alleged that because of the lack of sufficient training and guidance, registered representatives did not have the tools to present potential purchases with a side-by-side comparison of the fees and surrender charges or other information detailing the potential impact of the increased fee if the L-share contract was held by the customer for a long term. FINRA also alleged that the firm failed to establish, maintain, and enforce WSPs or provide sufficient guidance or training to registered representatives and principals on the sale of long term income riders with Multi-share Class VAs, particularly the combination of L-share contracts with long-term riders. On November 2, 2016, the Advisor entered into an Acceptance, Waiver, and Consent with FINRA without admitting or denying the allegations. A fine of $250,000 was paid to FINRA. FINRA Matter No. 202006674001. FINRA found that the firm failed to supervise a registered representative and to supervise the electronic communications of its associated persons. A registered representative formerly employed by the firm engaged in an undisclosed outside business activity. This business activity was an investment club conducted through an outside brokerage account that the registered representative did not initially disclose to the firm. FINRA found that when the representative later disclosed the account to the firm, the firm did not sufficiently investigate the activity in the account. FINRA also found that the firm did not properly investigate emails sent to and from the registered representative’s firm email address, resulting in a determination that from February 2014-February 2017, the firm failed to establish, maintain and enforce written supervisory procedures with respect to the review of electronic communications. On April 13, 2022, FINRA accepted a Letter of Acceptance, Waiver, and Consent submitted by the firm in which the firm accepted these findings without admitting or denying them. The firm consented to a censure and a fine of $175,000. SEC File No. 3-22142. Without admitting or denying the findings, the Firm consented to the entry of an Order Instituting Administrative and Cease-and-Desist Proceedings in which the Securities and Exchange Commission (“Commission”) found that the Firm failed to maintain and enforce certain policies and procedures concerning structured note recommendations and exception reporting related to these recommendations. The Commission further found that that as a result of these failures, the Firm failed to maintain and enforce written policies and procedures reasonably designed to achieve compliance with the Compliance Obligation of Regulation Best AMH/45242.v2 22  Interest, found in Rule 15l-1(a)(1) of the Securities Exchange Act. The Firm paid a civil money penalty of $325,000 on September 18, 2024. Other Financial Industry Activities or Affiliations First Horizon Advisors, Inc. is a registered investment adviser and a registered broker- dealer. We are a wholly owned subsidiary of First Horizon Bank (the “Bank”). Some officers of the Advisor, including members of the IC, are also registered representatives of First Horizon Advisors, Inc. and insurance agents of First Horizon Insurance Services, Inc. The Advisor provides investment advisory services to Bank customers at Bank financial centers. The Bank and/or its holding company, First Horizon Corporation, provide certain support services to the Advisor including accounting, legal and administrative services. First Horizon Bank Trust Division. The Advisor provides investment management services to the Trust Division of First Horizon Bank. First Horizon Advisors Model Portfolios are used by the Advisor in providing these services to the Trust Division. Investment management accounts are available through the Trust Division (“Agency Accounts”), that have similar strategies as the First Horizon Advisors Model Portfolios available through the MAS Program. Agency Accounts are established by entering into a separate Investment Management Agreement with the Trust Division. Fees and expenses for an Agency Account will be more or less than those of a First Horizon Advisors Model Portfolio Account available through the Program with a similar investment strategy. For Agency Accounts, different account opening minimums apply. Agency Accounts are administered and serviced at Trust Division locations by Trust Division personnel. IARs and FAs do not provide investment management services to Agency Accounts. The Trust Division will compensate an IP for referring a client to the Trust Division if the Trust Division opens an account, including an Agency Account, for the client. The compensation equals a percentage of the fees the Trust Division receives from the trust account, and it is credited to the IAR’s or FA’s production. First Horizon Bank. From time to time, the Bank will compensate an IP for referring a client to the Bank for certain financial products or services. Such compensation may be cash or non-cash compensation, and the compensation is paid by the Bank. Non-cash compensation may include prizes, travel, entertainment, and gift cards. Your IP may refer you to the Bank if you are interested in applying for a line of credit from the Bank secured by your Program Account. All credit decisions for this product are made by the Bank. Your IP will not be compensated for this referral. To pledge your securities as collateral for this line of credit, you will enter into an Account Control Agreement (“ACA”) with the Bank and First Horizon Advisors, Inc. Under the terms of the ACA, you agree that you will not withdraw assets from the Program Account except with prior approval of the Bank; and, that if the Bank provides First Horizon Advisors, Inc. with a “notice of exclusive control”, First Horizon Advisors, Inc. will follow instructions of the Bank with respect to the Program Account instead of instructions from you or your IP. AMH/45242.v2 23  Securities issued by First Horizon Corporation (FHC). First Horizon Bank, the parent company of the Advisor, is a wholly owned subsidiary of FHC. The Advisor does not make recommendations to buy or sell FHC securities. Code of Ethics The Advisor has adopted a Code of Ethics (the “Code”) which establishes standards of fiduciary conduct for its employees, including standards that apply to personal securities transactions. The Code requires compliance with policies concerning use and disclosure of non- public information and maintaining the confidentiality of customer information. The Code also requires that certain officers of the Advisor and employees who have access to non-public information concerning purchases and sales of securities for client accounts or recommendations for such purchases or sales (“Access Persons”) report their personal securities transactions. The Advisor receives reports of the transactions and an annual holdings report for each Access Person. Access Persons must receive prior approval from the designated compliance officer to serve as a director of a publicly traded company. These persons are not permitted to: • acquire securities in an IPO or private placement without obtaining prior approval from the designated compliance officer; • execute a transaction for their own account until any orders for the same security for an • advisory client’s account has been executed or withdrawn; recommend a security transaction for an advisory account without disclosing certain personal interests in such securities; • purchase or sell any security designated by the Chief Investment Officer (CIO) or designee during any black-out period as determined by the CIO or designee. The purpose of the prohibitions described above is to avoid any benefit an Access Person obtains from trading in a security prior to execution of a trade in the same security for a client’s account. You may obtain a copy of the Advisor’s Code of Ethics by contacting us at 901-818-6065 or 1-800-300-0987. Interest in Client Transactions Some mutual funds or ETFs pay shareholder servicing, 12b-1 fees or administrative services fees to the Advisor in connection with investment of the Account in shares of the mutual funds or ETFs (“Mutual Fund Fees”). Advisor has instructed NFS to rebate the Mutual Fund Fees to the Accounts that generated the Mutual Fund Fees. Cash awaiting investment in an Account will be invested in a money market fund (“Mutual Fund”) available through a sweep investment program provided by NFS. Account balances held in the Mutual Funds are included in the calculation of the Program Fee. Trade Execution All clients utilizing the MAS Program Account option are required to open a brokerage account through First Horizon Advisors, Inc. First Horizon Advisors, Inc. provides the brokerage account services-clearing and custody for the MAS Program Accounts under its existing clearing AMH/45242.v2 24  agreement with NFS. This arrangement allows the Advisor to utilize a provider with which the Advisor has had an established working relationship. The NFS arrangement permits the MAS Program to provide custody, execution, and investment management services for a single account level fee. The Advisor will monitor the execution of trades for the Accounts for accuracy, timeliness, and price. A portion of the Program Fee that the Advisor receives pays for the brokerage and custody services provided to the Accounts. You understand that by utilizing this arrangement, you forego any benefits in price or quality of execution obtained when a manager for an advisory account has discretion to select the executing broker for account transactions. The Advisor manages this potential conflict by regularly reviewing execution practices and quality of trades provided through the Program. For SMAs, the Sub-Manager will determine whether orders for an SMA will be aggregated with other accounts managed by the Sub-Manager. Consult the Sub-Manager’s ADV Part 2 for information concerning the Sub-Manager’s trading practices. For all other Program Accounts, Envestnet determines whether trades for a Program Account will be aggregated with orders for other accounts for which Envestnet executes trades. Envestnet’s trading practices are described in the Envestnet Wrap Fee Brochure. The Advisor pays NFS all charges and expenses associated with the trades for the Program Accounts. For the WealthBuilder accounts, First Horizon Advisor Model Portfolios, ADUMAs, and AMMAs, these expenses increase based on the number of trades. Under our clearing agreement with NFS, transaction charges are waived for certain mutual funds (NTF). As a result of this arrangement, the Advisor has a financial incentive in using NTF funds and/or limiting the trading activity for these Accounts. This conflict of interest is addressed by disclosure and by review of the Program Accounts as described in “Review of Accounts” below. The IC does not consider whether a fund is a NTF fund as a criteria for inclusion on the working list. The Advisor has a conflict of interest in utilizing NFS as its clearing broker for the Program Accounts. The pricing that we have negotiated with NFS for clearing and custody services is based upon us maintaining certain asset levels in certain types of brokerage accounts, and on annual trade volumes. We address this conflict of interest by monitoring trade execution as described above and through the Account reviews as described in “Review of Accounts” below. NFS provides financial assistance to us in the form of credits to the fees and charges billed to us under our clearing agreement. IRA Accounts are charged an annual IRA maintenance fee by NFS. NFS has agreed to pay a portion of such maintenance fee to us. NFS, will provide certain educational and marketing support to the Advisor and/or its IPs. Please see (Item 4) Services, Fees, and Compensation Sponsor Compensation for more information about these financial benefits. The expense ratio of the mutual fund share class is considered when selecting a mutual fund for your Account. Not all share classes of a mutual fund are available to Program Accounts. Share classes, share class expenses, and eligibility for investment in a share class change frequently. We periodically review the mutual fund share classes to determine if a share class with a lower expense ratio is available for our Program Accounts. If so, when reasonably practical, we will exchange the existing share class in an Account for a share class with a lower expense ratio. AMH/45242.v2 25  In the event of a trade error on the part of the Advisor, the Advisor will correct the error by executing the appropriate trades for the client’s Account and for the Advisor’s account. The Advisor will reimburse the client’s Account for any market loss incurred as a result of the error. In the event the trades executed for the Advisor’s account to correct an error results in a gain for the Advisor’s account, the Advisor will retain such gain. Review of Accounts The Advisor has designated certain employees as “Advisory Account Reviewers”. Each Account is reviewed by an Advisory Account Reviewer prior to opening an Account. The client’s investment profile is also reviewed to confirm that the investments and asset allocation recommended for the Program Account align with the client’s time horizon, risk tolerance, and investment objectives. The IC maintains a working list of mutual funds and ETFs. This list is reviewed at least annually. Certain designated employees of the Advisor (the “IRG”) are responsible for monitoring the AMMA performance and reporting such information to the IC. We will notify you at least quarterly to contact your IP if there have been any changes in your financial situation or investment objectives, or if you wish to impose or modify restrictions concerning management of your Account. We will contact you at least annually to set up a meeting or interview to review your Account status, and to discuss any changes in your financial circumstances and goals. Reports NFS is custodian and clearing broker for all Accounts. The Custodian provides you a periodic statement for all transactions effected for your Account at least quarterly. Envestnet provides you a quarterly performance report. Client Referrals Please see (Item 4) above Services, Fees, and Compensation- Compensation, Financial Benefits and Conflicts of Interest, First Horizon Bank for more information concerning compensation Bank employees can receive in connection with referring clients to the Advisor and/or obtaining investment management services from the Advisor. For information concerning referral fees paid to IPs, please see (Item 9) above Additional Information – Other Financial Industry Activities or Affiliations, First Horizon Bank Trust Division; First Horizon Bank. NFS, will provide certain financial benefits to the Advisor and/or its IPs. See (Item 4) Services, Fees, and Compensation- Sponsor Compensation. Financial Information The Advisor has no financial commitments that impair its ability to meet contractual and fiduciary obligations to its clients. The Advisor has not been the subject of a bankruptcy proceeding. AMH/45242.v2 26