GEOWEALTH MANAGEMENT LLC

GeoWealth Management, LLC Form ADV Part 2A CRD # 148222 444 N. Michigan Avenue, Suite 3150 Chicago, IL 60611 November 2025 This Form ADV Part 2A (the “Brochure”) provides information about the qualifications and business practices of GeoWealth Management, LLC (“GeoWealth” or “Firm” or “we”). If you have any questions about the contents of this Brochure, please contact us at (312) 219-9160 or by email at evan.lieberman@geowealth.com. You may also visit our website at www.geowealth.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. GeoWealth is a registered investment adviser. Registration of an Investment Adviser does not imply that GeoWealth or any of its principals or employees possess a particular level of skill or training in the investment advisory business or any other business. Additional information about GeoWealth is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes In March 2025, GeoWealth filed with the SEC the last update of its Brochure in an annual amendment with material changes outlined. This amended brochure contains the following material changes. Item 10 has been updated to disclose that Apollo Management Holdings, L.P., has made an investment in GeoWealth. Further, GeoWealth, LLC, GeoWealth’s parent company, has entered into commercial partnerships with J.P. Morgan Asset Management, Apollo Management Holdings, L.P., Blackrock Investment Management.. Item 14 has been updated to disclose that GeoWealth has entered into arrangements with certain third-party model managers, money managers, and alternative investment providers (“Third- Parties”) that allow advisors to access certain GeoWealth services either at no cost or at a reduced cost. For other Third Parties, GeoWealth receives compensation solely based on the assets invested in their products. This creates a conflict of interest which is further disclosed in Item 14. Item 14 has been updated to remove a disclosure about promoter agreements which is no longer applicable. Item 17 has been updated to clarify that GeoWealth uses a proxy advisory firm to assist in voting proxies. When GeoWealth votes proxies for a client account, GeoWealth votes on all securities in the client account regardless of whether the securities are in a managed model. 2  Item 3 – Table of Contents Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 3 Item 4 – Advisory Business .................................................................................................................................... 4 Item 5 – Fees and Compensation......................................................................................................................... 5 Item 6 – Performance Fees .................................................................................................................................... 7 Item 7 – Types of Clients ....................................................................................................................................... 8 Item 8 – Methods of Analysis, Sources of Information, Investment Strategies, Risk of Loss ................ 8 Item 9 – Disciplinary Information ...................................................................................................................... 13 Item 10 – Other Financial Industry Activities and Affiliations ..................................................................... 13 Item 11 – Code of Ethics, Participation/Interest in Client Transactions, Personal Trading ................ 14 Item 12 – Brokerage Practices ............................................................................................................................ 15 Item 13 – Review of Accounts ............................................................................................................................ 17 Item 14 – Client Referrals and Other Compensation .................................................................................. 18 Item 15 – Custody ................................................................................................................................................. 18 Item 16 – Investment Discretion ....................................................................................................................... 19 Item 17 – Voting Client Securities ..................................................................................................................... 19 Item 18 – Financial Information .......................................................................................................................... 21 3  Item 4 – Advisory Business GeoWealth Management, LLC (“GeoWealth”) is a limited liability company organized in 2004 under the laws of the State of Delaware. The Firm is registered as an investment advisor with the SEC pursuant to the Investment Advisers Act of 1940 (“Advisers Act”). GeoWealth Holdings, LLC is the majority owner of GeoWealth through the subsidiaries GeoWealth Enterprises and GeoWealth, LLC. GeoWealth operates a Turnkey Asset Management Platform (“TAMP”) and provides digital advisory tools that investment advisers rely on for managing their client accounts. In a TAMP, clients typically work directly with their primary investment adviser to determine their investment needs given their unique circumstances. The primary investment adviser then relies on GeoWealth to purchase and sell securities through the use of model portfolios and perform various other functions. This enables investment advisers to focus their efforts on the individual needs of their clients. Typically, advisers will engage with GeoWealth in a sub-advisory or co-advisory capacity, however in certain circumstances clients will work directly with GeoWealth. GeoWealth is able to provide not only investment management services, but GeoWealth can also handle the operational aspects of account opening and administration. These services include but are not limited to account opening and closing, interactions with the custodian, maintenance of account paperwork, processing of contributions and withdrawals, Roth conversions/IRA recharacterizations, account transfers, quarterly billing and performance reporting. These services are typically provided to advisers under a co-advisory relationship. In a direct advisory relationship, GeoWealth, as an SEC Registered Investment Adviser, offers consulting and investment supervisory services on managed investment accounts to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, business entities and corporations (the “client” or “client account” or “end-client). For the small number of end-clients working directly with GeoWealth, the investment supervisory services include regular analysis and review of portfolios and advice concerning acquisition, retention, management, reinvestment and disposition of cash, securities and other assets of the client’s portfolios. When investing model portfolios, GeoWealth generally has the discretion to determine when to purchase or sell securities and whether to accept the recommendation of the model provider. It is GeoWealth’s standard practice to invest all model portfolios in accordance with the recommendation of the model provider. For end-clients who work directly with GeoWealth, we will work with the client to understand the client’s financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. Once the client’s investment portfolio has been designed and investments have been allocated, we will provide ongoing portfolio review and management services. Clients can place reasonable restrictions on their investment portfolio such as transferring in securities to be held long-term and not sold. Such restrictions must be provided in writing to, and accepted by, GeoWealth. Our model marketplace offers risk-based, thematic and outcome-based third-party models from industry-leading providers. Our model marketplace also offers access to alternatives and fixed income products which typically require additional enrollment paperwork. Through our TAMP and model universe, we ensure advisers have scalable solutions to respond to client needs. Additionally, 4  we offer our own proprietary models and provide advisers with the ability to offer their own proprietary models which GeoWealth services on their behalf. GeoWealth, in certain relationships with ERISA accounts, is section 3(38) “investment manager”. GeoWealth provides its 3(38) investment management services to ERISA Plans of advisers that it works with, that are on various record-keeping platforms. These services are not open to new clients. The 3(38) investments provided include, but are not limited to, certain of GeoWealth’s Model Portfolios, an investment line-up using securities representing a spectrum of asset classes and risk levels, and a qualified default investment alternative (or “QDIA") for the Plan, if required. We provide investment advice on either a discretionary or non-discretionary basis. As of December 31, 2024, GeoWealth managed approximately 4.8 billion of regulatory assets on a discretionary basis and approximately 8.8 billion of regulatory assets on a non-discretionary basis. Item 5 – Fees and Compensation In a sub-advisory relationship, fees are determined by an agreement between the primary investment adviser and GeoWealth. In a direct advisory relationship with GeoWealth, the fees charged are determined by an agreement between GeoWealth and the end client. Fees charged are negotiable. GeoWealth offers several different products/services for investment advisers and their clients. Each product/service provided can be billed separately (“à al carte”), using a maximum fee model (“Flat Fee”), or at a single enterprise-level fee. GeoWealth does not offer a wrap fee program where clients are charged a single, bundled fee. Therefore, clients may be charged separate fees for investment advice, brokerage services, administrative expenses, and other fees and expenses. When billed separately, fees include but are not limited to: platform fees, money manager fees, and per account fees. The maximum platform fee is 0.5% and the maximum per account fee is $100 per account per year. The money manager fee rate is dependent on the fee rate set by the money manager and will vary. When billed a Flat Fee, GeoWealth is compensated at an annual fee of up to 0.35% per account with a maximum client annual household flat dollar fee depending on the services provided. Fees for households that are in excess of $3 million are charged an additional fee of $500 for each $1 million over $3 million. When billed as a single enterprise-level fee, the fee rate is customized based on the adviser’s unique circumstances. The fee schedule often includes a minimum fee that will vary depending on the circumstances surrounding the relationship. When working directly with GeoWealth, the investment advisory fee will not exceed 2.5%, however it is unlikely that anyone would be charged the maximum fee. When GeoWealth models are offered through other platforms, each platform can control the fee rates. Currently, for the other platforms our models are available through, fees range from 0.15% - 0.25% of assets under management. Please consult the platform from which you are accessing 5  GeoWealth models to obtain their fee rates and their fee deduction and refund methodologies. These services are not open to new clients. Subject to an agreement with each client’s investment advisor, accounts can be charged a minimum account fee. Each investment adviser working with GeoWealth can select the billing methodology and timing of their choice. Some clients have their fees debited by GeoWealth, and other clients have their fees debited or invoiced by their investment adviser. GeoWealth’s fees are charged monthly in arrears, quarterly in arrears, monthly in advance, or quarterly in advance. Any billing methodology must be mutually agreed upon by the client’s investment adviser and GeoWealth. GeoWealth and each client’s investment adviser can mutually agree to debit fees either in advance or arrears. Should an investment advisory relationship end prior to completion of the advance billing period, clients are entitled to a refund for unearned investment advisory fees. The amount of each client’s refund is calculated based on the following inputs: dollar value of the account, outflows or inflows of assets, number of days in the billing period elapsed, and billing rate. GeoWealth will calculate the fee refund and facilitate a credit to the client for it. Given the unique aspects of each client’s billing configuration, the inputs used may vary. Client accounts are held at a qualified custodian. Qualified custodians charge various fees that are in addition to fees charged by GeoWealth. These fees can include but are not limited to, ticket charges, trade commissions, and other transaction fees. Note that certain qualified custodians may no longer charge trade commissions, however that is determined by each client’s unique relationship with their custodian. Please see Item 12 – Brokerage Practices for more detailed information. The individual investments held within each client’s account may charge fees in addition to the fees charged by GeoWealth and each client’s qualified custodian. For example, ETFs typically charge management fees to cover their investment advisory functions as well as fees for operating and administrative expenses. These fees, typically referred to as an “Expense Ratio”, are generally deducted from the investment value and are not charged by GeoWealth. Additionally, investment model managers, including GeoWealth, may charge additional fees on top of those fees charged by ETF providers. Some of those fees are negotiable. Please read Item 8 for more information about the investment process surrounding model portfolios. Clients should read each investment’s prospectus or similar document to obtain a detailed understanding of its fees and expenses as well as other important information. Clients are responsible for all custodial fees and any fees associated with mutual funds and other transactions. When fixed income securities, such as Corporate and Municipal bonds, are purchased or sold, the executing broker is compensated for the execution of the security through a bid-ask spread. In other words, if you are purchasing Municipal Bond, the executing broker purchases it from the seller at a specified price and sells it to you at a higher price. Each transaction for a fixed income security is negotiated directly between GeoWealth (or our agent) and the executing broker. GeoWealth offers customized index portfolios. The customized index portfolios are described in Item 8. The fee for a Customized Index Portfolio is up to an additional 0.35% of assets under management. Our fee for 3(38) services is an annual 0.07% of assets under management, per plan, which is subject to negotiation based on the customized needs of the plan. These services are not open to new clients. 6  When GeoWealth calculates an asset-based fee, the value of the assets is calculated using the price maintained within our platform. In certain circumstances, a particular security may have different prices at different pricing sources. GeoWealth’s platform only maintains a single price for each security for each day. Each client’s custodian may use a different pricing source than GeoWealth and therefore the prices used in a client’s custodial statement may not be the same as the GeoWealth platform. Therefore, the asset-based fee charged to a client account may be different than if that fee was calculated using the prices obtained directly from the client’s qualified custodian. GeoWealth may receive valuation updates for certain securities, such as private investments, after billing has been completed. Such securities will be billed at the valuation on hand at the time the billing was processed and will not be retroactively adjusted. Each client’s investment adviser can manually input securities to display on the GeoWealth platform. For example, advisers may wish to display insurance products or annuities and other items that we are unable to receive a data feed for. Your adviser is solely responsible for updating those values and clients should discuss with adviser whether the clients are billed on those values. The prices used in the platform are determined using a hierarchy that is consistently applied each day. For example, the platform will first attempt to obtain a price from pricing source 1. If a price is not available for a security held in a client portfolio, the platform will attempt to obtain a price from pricing source 2. If a price is not available from pricing source 2 for a security held in a client portfolio, the platform will continue down the list of available pricing sources in this manner until all pricing sources are exhausted. In the event that a price is incorrect due to a data vendor discrepancy or has not been provided by any of the available electronic pricing sources, we will seek to determine the pricing using other publicly available pricing sources. Each financial adviser using the GeoWealth platform has the ability to choose unique billing settings for their client’s portfolios. The billing settings available are limited depending on the type of services selected by the Adviser. Billing settings are highly customizable and include the ability to change the fee rates based on asset classes, sub-accounts, securities, margin balances, and also include the ability to bill on cash, among other settings. Additionally, each adviser may choose to calculate their fees in arrears or in advance and may calculate the billable value using the average daily value, flow adjusted intervals, or start or end of period values. By default, all assets in client accounts are billed on net of margin balances. Any changes to an adviser’s standard billing rates and practices are directly negotiated between the adviser and their end client. Clients should read their investment management agreement closely and understand their financial adviser’s billing settings. Some model managers offered on the GeoWealth platform have the option to pay for the cost of the GeoWealth platform that would have been charged to each client or to client’s adviser. Clients are encouraged to check with their adviser about whether the model manager has paid for GeoWealth’s platform fees and discuss any conflict of interest it creates for them. Item 6 – Performance Fees GeoWealth does not charge performance-based fees for advisory clients. 7  Item 7 – Types of Clients As described in Item 4 – Advisory Business of this Brochure, GeoWealth is both a technology provider and SEC registered investment adviser. We offer a comprehensive suite of services directly to other registered investment advisers and advisory services directly to end clients. Depending on our relationship with the investment adviser, our relationship with the end client may be either through a solicitation arrangement, sub-advisory agreement, co-advisory agreement, or direct advisory contract. End clients are generally individuals, high net worth individuals, trusts, family offices, corporations, and other business entities. GeoWealth does not have a minimum account size. However, to invest in certain models, there may be minimums imposed. Please inquire about any individual investment options with GeoWealth or your investment adviser. Item 8 – Methods of Analysis, Sources of Information, Investment Strategies, Risk of Loss GeoWealth’s Investment Solutions business is designed to provide flexibility and choice when it comes to investment management. GeoWealth offers financial advisers the ability to build and manage their own model portfolios (adviser-managed models), invest in third-party model portfolios, invest in GeoWealth’s own proprietary model portfolios or UMAs, or designate third-party separately managed account managers (“SMA Managers”). A model is a collection of individual securities specifically chosen with the goal of achieving a particular investment objective. The decision about which model(s) to offer is made at the sole discretion of each client’s financial adviser. (1) “Adviser-Managed” Models: The financial adviser is the portfolio manager. These model portfolios consist of one or more investments in single stocks, ETFs and/or mutual funds. GeoWealth trades the model portfolios as directed by the financial adviser but has no investment discretion and does not choose the securities included in these models. (2) “Third-Party” Models*: A third-party asset manager or strategist is the portfolio manager and the portfolio is traded by GeoWealth. Models can contain ETFs, mutual funds, stocks, bonds, structured notes, and alternatives. (3) GeoWealth Models: GeoWealth is the portfolio manager. We manage these portfolios using our own proprietary research and analysis processes. (4) Models traded by Third Party Managers *: A third-party investment adviser acts either as a sub-adviser or direct adviser over the account and makes all investment decisions in accordance with each end-client’s risk profile and investment objectives. SMA models can contain a broader range of securities, such as individual bonds and options. The SMA manager trades these models. (5) GeoWealth Unified Managed Account (UMA) portfolios: GeoWealth designs and constructs portfolios of “Third-party” and/or GeoWealth models. All components of the UMA are traded by GeoWealth. 8  *In instances where GeoWealth uses an unaffiliated sub-adviser (SMA models) to manage the assets of an end-client, end-clients have the choice to receive the sub-adviser’s Form ADV Part 2A directly or have GeoWealth receive it on the end-client’s behalf. Unless instructed otherwise, GeoWealth will receive the sub-adviser’s Form ADV Part 2A on behalf of the end-client. GeoWealth regularly monitors all sub-adviser’s Form ADV Part 2A and will disclose any material conflicts of interest or concerns that we identify. Should an end-client want to view any sub-adviser’s Form ADV Part 2A, we remind them that they are available at https://adviserinfo.sec.gov/. 1) ADVISER MANAGED MODELS The adviser creates and manages their own model portfolio consisting of investments such as single stocks, ETFs, and/or mutual funds. The investment adviser uses their own independent analysis to determine which securities to invest client assets in and which models to offer to their clients. GeoWealth trades the models as directed by the financial adviser but has no discretionary investment authority over those assets. 2) THIRD-PARTY MODELS Third-party models offered in our model marketplace fall into three general categories: Tier 1,Tier 2 and Custom. GeoWealth conducts different levels of due diligence for models in Tier 1, Tier 2 and Custom. GeoWealth urges investment advisers to understand the level of diligence performed by GeoWealth and perform their own supplemental diligence such that they have a satisfactory understanding of the investment products and risks before recommending them to clients. GeoWealth collects an annual DDQ from all Tier 1 and Tier 2 managers. Tier 1 For all Tier 1 managers, GeoWealth obtains an understanding of the firm, investment offerings, investment philosophy and investment processes. Before onboarding and distributing Tier 1 models, GeoWealth collects and reviews a comprehensive due diligence questionnaire, ensures that each model manager is a registered investment adviser (RIA) and checks for any material regulatory disclosures in the ADV. This review is performed at the onset and again annually thereafter. Tier 2 Tier 2 models are designed to provide access to a broad range of managers and models. Before onboarding and distributing Tier 2 managers, GeoWealth collects and reviews a shortened due diligence questionnaire, ensures that each model manager is a registered investment adviser (RIA) and checks for any material regulatory disclosures in the ADV. Custom Third-party custom models operate differently than Tier 1 and Tier 2. Custom models may not be available to all investment advisers. In this scenario, the investment adviser and third-party asset manager collaborate directly through their own direct relationship with the model manager. The GeoWealth platform serves as the technology for delivering the custom models that the asset manager has developed directly with the investment adviser. GeoWealth is not responsible for any 9  manager due diligence for custom models which must be performed by the client’s investment adviser. 3) GEOWEALTH MODELS GeoWealth offers our clients a broad range of proprietary models that invest in ETFs. Our models generally fall into the following categories: Strategic Risk-based, Income, Multi-Factor, Strategic Reserves, and Stable Return. Models may include ETFs that represent US stocks, international stocks, US fixed income, international fixed income, real estate, commodities, managed futures and more. • Strategic Models are a set of model portfolios across a risk continuum from conservative (higher allocation to fixed income or all fixed income) to aggressive (higher allocation to equities or all equities). Each model portfolio has a different risk profile to broadly align with an individual client’s risk profile. We also offer tax-sensitive versions of our strategic models. • Multi-Factor Models also use a strategic approach to asset allocation but have been built to emphasize factor exposure. Factors are characteristics shared by groups of securities that distinguish them from other securities. Examples include “value,” “size,” “quality,” and “momentum.” We have two sets of factor portfolios: one set utilizes factor-based funds from various mutual fund providers, and one set utilizes only Dimensional mutual funds. Dimensional Fund portfolios are only available to advisers who have been pre-approved by DFA. • The Short-Term Reserve Model is designed for investors who want to hold assets in a highly liquid form with relatively little downside risk. The portfolio is invested primarily in exchange-traded funds (ETFs) and/or mutual funds that invest in short-term fixed income securities. Some of those funds will be designed to track indexes and others will be actively managed. • The Stable Return model is a primarily fixed income ETF model that dynamically allocates across a diversified spectrum of income-producing asset classes. The model is updated monthly based on a systematic process. GeoWealth’s Investment Solutions team is responsible for selecting ETFs within the GeoWealth model portfolios. Our due diligence processes use both quantitative and qualitative factors. Index- weighted ETF selection is mostly quantitative. We also use actively managed ETFs within some of our model portfolios; these funds are not index-tracking and their performance can differ substantially from that of traditional market-cap-weighted indexes. Active ETF fund selection can have a heavier qualitative assessment on the strength of the portfolio management team. 4) MODELS TRADED BY THIRD PARTY MANAGERS A third-party asset manager acts either as a sub-adviser or direct adviser over the account and makes all investment decisions in accordance with each end-client’s risk profile and investment objectives. 10  For Index Portfolios (also known as direct indexing), the adviser provides relevant information to the asset manager to create an investment strategy that takes into consideration various client specified constraints and preferences, while seeking to quantify and minimize the tracking error to a defined index (or blend of indexes). An Index Portfolio is made up of individual stocks and includes, but is not limited to ESG/Impact customization, factor tilts, single-stock exclusions/inclusions, and regional constraints. 5.) GEOWEALTH UMA (UNIFIED MANAGED ACCOUNT) PORTFOLIOS GeoWealth designs and constructs portfolios of “Third-party” and/or GeoWealth models. All components of the UMA are traded by GeoWealth. The current GeoWealth UMAs invest in third-party and GeoWealth models selected by the Investment Solutions Team. Underlying models may include ETF and stocks that represent US equity, international equity, US fixed income, international fixed income, real estate, commodities, managed futures and more. Risk of Loss Factors Investing in securities involves risk of loss that clients should be prepared to bear. Clients may lose some or all of their principal and generate less income than anticipated or no income at all. In general, risks include: market risk, interest rate risk, issuer risk, liquidity risk, and general economic risk. Although we manage the assets in a manner consistent with risk tolerances, there can be no guarantee that the future anticipated performance of any investment will occur. There is also a risk that the portfolios will not achieve their specific investment objectives. There is a risk that index-oriented funds included in portfolios will not precisely track the performance of the indexes they are intended to replicate. The following are material risks related to our investment strategies. This list does not purport to be a complete enumeration or explanation of every possible risk associated with our investment strategies. Equities The risk that events negatively affecting issuers, industries or financial markets in which an underlying fund or separate account invests, will negatively impact the value of the stocks held. Fixed Income The risk that fluctuations in interest rates or events negatively affecting the issuers, industries or financial markets in which the security is exposed to will cause the value of fixed-income securities held to decline. 11  Alternatives Alternative investments take on many forms and each private investment has its own risk of loss factors. In general, alternative investments lack the transparency of other investment types, have less regulatory reporting requirements, are illiquid, and have special tax considerations, among other risks. International Securities The possibility that international stocks may be adversely affected by political and social instability, changes in economic, governmental or taxation policies, difficulty in enforcing regulations or claims, decreased liquidity or increased volatility. Small to Medium Capitalization Companies GeoWealth may invest a portion of client assets in the stock of companies with small to medium- sized market capitalizations. While GeoWealth believes these investments often provide significant potential for appreciation, those stocks (particularly smaller-capitalization stocks), involve higher risks in some respects relative to investments in stocks of larger companies. For example, prices of such small-capitalization stocks are often more volatile than prices of large-capitalization stocks. In addition, if the stock is not traded frequently, there is a chance that the purchase price or sale price will be impacted by the lack of liquidity. Lack of Diversification Client portfolios may not be widely diversified among sectors, industries, geographic areas or types of securities. Further, client portfolios may not necessarily be diversified among a wide range of issuers. Accordingly, the portfolios will be subject to more rapid change in value than would be the case if the portfolio was highly diversified. Portfolio Turnover Depending on the investment strategy selected, it is possible that GeoWealth will need to trade in and out of securities frequently. If the investment strategy selected requires this, transaction-related charges may negatively impact the portfolio return. Short-Sales GeoWealth may affect short sales. Short sales can, in certain circumstances, substantially increase the impact of adverse price movements on a portfolio. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, which could result in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Leverage While not typical, GeoWealth may trade on margin or engage in other forms of borrowing to affect the purchase of securities in a portfolio. The level of interest rates and the rates at which client accounts can borrow will affect their returns. Fluctuations in the market value of the portfolio of a 12  heavily leveraged account can have a disproportionately large effect on the account value. For more information regarding the specific risks that are associated with a particular investment, clients are encouraged to consult the offering documents or similar disclosures. Item 9 – Disciplinary Information GeoWealth does not have any disciplinary information to disclose in this section. Specifically, there are no criminal or civil actions, administrative enforcement proceedings, or self-regulatory organization enforcement proceedings to be disclosed. Item 10 – Other Financial Industry Activities and Affiliations JPMC Strategic Investments Group I Corporation (an affiliate of J.P. Morgan Asset Management), Apollo Management Holdings, L.P., and Blackrock SMI, LLC (an affiliate of Blackrock Investment Management), each own a minority interest and have commercial partnerships with GeoWealth, LLC, GeoWealth’s parent company. As part of its own due diligence, GeoWealth annually reviews securities for inclusion in its own model portfolios. J.P. Morgan Asset Management, Blackrock Investment Management, and Apollo Management, as well as other asset managers, are eligible to receive placement in GeoWealth’s models based upon our own due diligence. Please see Item 14 – Client Referrals and Other Compensation which discusses conflicts of interest relevant to the placement of these securities in GeoWealth models. GeoWealth entered into an agreement with 55 Institutional Partners, LLC (“55IP”) to provide tax-loss harvesting, tax-aware transitions, tax aware withdrawals, and other tax conscious portfolio management solutions. 55IP is a wholly owned subsidiary of J.P. Morgan Asset Management whom, as explained above, owns a minority interest in GeoWealth, LLC. GeoWealth does not receive any compensation for offering any of 55IP’s services. Effective March 31, 2023, GeoWealth Management LLC’s (“GeoWealth”) parent company, GeoWealth, LLC, acquired First Ascent Asset Management, LLC (“FAAM”). FAAM was an investment adviser registered with the SEC. Effective March 22, 2024, GeoWealth took over the investment advisory business of FAAM and all FAAM clients are now investment advisory clients of GeoWealth. Effective August 1, 2025, GeoWealth’s parent company, GeoWealth, LLC, acquired a majority of TAMP assets from Freedom Advisors. 13  Item 11 – Code of Ethics, Participation/Interest in Client Transactions, Personal Trading Code of Ethics & Personal Trading Pursuant to Rule 204A-1 of the Advisers Act, GeoWealth has adopted a Code of Ethics that establishes how we hold ourselves out as having a high standard of ethical conduct and how we serve as a fiduciary to our clients. Key aspects of our code of ethics include handling conflicts of interest, gifts and entertainment, political contributions, employee trading, privacy, and insider trading, among other items. GeoWealth recognizes and believes that (i) high ethical standards are essential for its success and to maintain the confidence of its clients; (ii) its long-term business interests are best served by adherence to the principle that the interests of clients come first; and (iii) it has a fiduciary duty to its clients to act solely for the client’s benefit. All GeoWealth employees must put the clients’ interests before their own personal interests and must act honestly and fairly in all respects in dealings with clients. All GeoWealth employees must also comply with all federal securities laws. In general, employees (and members of their immediate households) must obtain written pre- approval from the Chief Compliance Officer (“CCO”) or their delegate prior to executing a personal transaction in equity securities, ETFs, options, and futures. The spirit of the Code of Ethics is to discourage frequent trading in employee personal accounts. In addition, employees must receive pre-approval from the CCO or their delegate to acquire securities for their own account in an initial public offering. Employees must also obtain pre- approval from the CCO or their delegate before engaging in any outside business activities or private placements. Certain highly liquid index tracking ETFs do not require pre-approval. All employees must provide duplicate copies (when available) to the CCO or their delegate of brokerage statements for accounts over which the employee has discretion. These records are used to monitor compliance with the foregoing policies. Employees must also annually attest to the location of their holdings. These policies apply to any personal transactions involving certain equity, debt, options, and futures (or derivative products related to these securities). This policy does not apply to transactions involving government securities, open-end mutual funds, or other instruments which afford the investor no discretion over individual securities transactions. GeoWealth strictly prohibits the misuse or inappropriate communication of inside information in connection with securities transactions. GeoWealth, as well as federal and state securities laws, also prohibit the practice of market manipulation (defined as action intended to deceive or defraud investors by controlling or artificially affecting the price of securities). In special situations, GeoWealth will create an information barrier or a “Chinese Wall” procedure that restricts the disclosure of confidential information to those who have a genuine “need to know”. The Firm has also adopted communications guidelines designed to assist personnel in understanding their duties and responsibilities regarding the receipt and the communication of financial and other sensitive information. 14  GeoWealth restricts the giving and receiving of gifts, limiting participation in and sponsoring of entertainment events, and requires the reporting of gifts and entertainment to the CCO or their delegate subject to certain exceptions. GeoWealth also has a policy that governs political contributions to certain officials and political parties. This policy is designed, among other things, to address the requirements of Rule 206(4)-5 under the Advisers Act. Our Code of Ethics is available upon request. Participation or Interest in Client Transactions Employees of GeoWealth can own securities in their personal accounts that are also recommended by GeoWealth. The Firm has established procedures intended to limit conflicts of interest in cases where GeoWealth or any of their employees buys or sells securities recommended by GeoWealth to our clients. GeoWealth does not engage in principal trading and does not recommend securities to advisory clients it has a proprietary or ownership interest in. However, subject to GeoWealth’s Code of Ethics, employees may purchase and sell securities either recommended by GeoWealth or held in models maintained on the GeoWealth platform. ERISA When we provide investment advice to Clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with our clients’ interests, so we operate under a special rule that requires us to act in our clients’ best interest and not put our interest ahead of yours. Under this special rule, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Item 12 – Brokerage Practices Best Execution As a fiduciary, the Firm has an obligation to seek best execution of transactions under the circumstances. To fulfill this duty, GeoWealth must seek to execute securities transactions for clients 15  in such a manner that total costs or proceeds in each transaction are the most favorable under the circumstances. Best execution is determined on a trade-by-trade basis and will result in the best qualitative execution, not necessarily only the lowest possible commission cost. In selecting brokers and dealers to affect portfolio transactions for the clients, we will consider such factors as the ability of the brokers or dealers to affect the transactions, their capabilities, reliability, and financial responsibility, among other factors. Clients have different investment strategies, objectives, and parameters, therefore, it is possible that certain clients may hold securities that other clients do not, or certain client accounts may be long a particular security while others may short that same security. GeoWealth will treat all clients fairly and equitably when allocating investment opportunities such that no client is favored over another. Order Aggregation Aggregated or “batched” trades will be used to facilitate best execution, which includes negotiating more favorable prices, obtaining more timely or equitable execution, or reducing overall commission charges. All clients participating in the aggregated order will receive an average share price. Orders are aggregated using the following procedure: 1. All accounts that require a transaction in a particular security are identified and the trade is appropriately sized. 2. All participating accounts are blocked into their respective groups. Various factors determine which accounts are permitted to be traded in block. Those factors include, but are not limited to: custodian, custodian master account association, designated broker, and account size. At the trader’s discretion, orders created after a particular block is created may be combined with the block if it will not materially disadvantage the clients in the existing block order. However, such a process is not a requirement. Additionally, at the trader’s discretion, accounts requiring trades to be placed prior to the execution of a block trade (i.e. time sensitive wire, unexpected cash raise needed prior to market close, etc.) may be executed on demand and therefore not participate in a block order. When executing trades, GeoWealth uses a broker rotation program. The order in which trades are executed is set in advance and the rotation order is advanced each day. The broker rotation program attempts to ensure that no particular client account or advisory relationship receives preference when executing trades. At the trader’s discretion, the broker rotation order may be altered if placing trades in that order would materially disadvantage another client/batched order. Examples necessitating altering the broker rotation schedule include but are not limited to, a particular broker encounters technical problems and is temporarily unable to receive orders, a block trade is not complete or is only partially complete at the start of particular order execution window, a block contains a security that will require extended execution time and therefore delay the execution of other orders, among other reasons. GeoWealth also provides trade signals for its models to 3rd party platforms. If model updates are done during market hours, trade signals will be disseminated to the 3rd party platform using a trade rotation program as described above. If trade signals are disseminated outside of market hours, it 16  shall not be necessary to use a trade rotation program however all model signals will be disseminated before the end of that business day. Trade dissemination to 3rd party platforms will be done after GeoWealth accounts have had an opportunity to trade the relevant models. GeoWealth does not currently engage in cross-transactions. However, in the future if GeoWealth causes a client to buy or sell securities directly from or to another client in such a way that it is classified as a cross-transaction, it will be done in accordance with rule 206(3). Clients are permitted to specify the broker used to trade their account. This is often referred to as “directed brokerage.” If a client does direct brokerage, the client may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices. Soft Dollars The term “soft dollar” arrangements is generally used to describe an agreement that involves a transaction between an investment adviser and a broker-dealer, whereby a broker-dealer provides the investment adviser with research or other services or products in return for commission dollars paid for executing transactions for client accounts. In providing research services, the broker-dealer may produce these “in-house” or obtain them externally from third-parties. Research products and services provided may include research reports on particular industries and companies, economic surveys and analyses, financial and industry consultants and advisers, etc. Currently GeoWealth does not receive any soft dollar benefits. However, it is GeoWealth’s policy to stay within the safe harbor provisions of 28(e) Securities Exchange Act of 1934 should the Firm do so in the future. Model Manager Holding Dissemination When 3rd party managers disseminate model holdings and/or updates to their model holdings, they send them to multiple different parties. Each 3rd party manager uses their own procedures to determine who receives the holdings/updates and in what order. Sometimes, the manager’s dissemination procedures require them to disseminate their trades with affiliated firms and advisers prior to disseminating them to 3rd parties such as GeoWealth. When this occurs, clients of GeoWealth may trade after affiliates of the 3rd party managers have had an opportunity to trade. This may be disadvantageous to clients of GeoWealth since they may be subject to unfavorable price movement resulting from the trades of the 3rd party managers. When trade allocations are provided by 3rd party model managers, we will obtain an understanding of their allocation procedures to ensure that no clients are systematically disadvantaged. Item 13 – Review of Accounts All Client accounts in a direct advisory relationship with GeoWealth are reviewed on at least an annual basis to ensure conformity with Client objectives and guidelines unless the client and adviser 17  mutually agree otherwise. These accounts are regularly monitored in response to changes in investment objectives by the client or as deemed appropriate in light of market conditions. For all accounts, we periodically review them to ensure consistency with the trading instructions received. Reviews are performed by members of GeoWealth’s trading team whose compliance with SEC rules and regulations is ultimately overseen by the CCO. Generally, clients will receive detailed account reports from GeoWealth or each client’s investment adviser on a monthly or quarterly basis via electronic delivery. These reports are supplemental to the statements provided by each client’s qualified custodian. A standard reporting package includes a performance summary, holdings summary, and a fee summary. Each client’s investment adviser has the ability to change which reports are provided based on the unique needs of the client and/or adviser. Item 14 – Client Referrals and Other Compensation GeoWealth has entered into arrangements with certain third-party model managers, money managers, and alternative investment providers (“Third-Parties”) that allow advisors to access certain GeoWealth services either at no cost or at a reduced cost. Under these arrangements, the Third Parties compensate GeoWealth for the advisor’s use of the GeoWealth platform. For other Third Parties, GeoWealth receives compensation solely based on the assets invested in their products. The list of Third-Parties changes from time to time and is available upon request. These payments can take the form of either (i) a fee paid by the Third-Party to GeoWealth to offset the fees that GeoWealth would otherwise charge advisors, or (ii) a payment based on a percentage of assets in Third Parties products, or both, and can be subject to minimums. Whenever GeoWealth receives compensation directly from a Third Party, a conflict of interest arises because GeoWealth is incentivized to promote Third Parties that result in greater compensation to GeoWealth than other investment options. Although this conflict exists, GeoWealth does not have the authority to select investment models for clients within co-advisory or sub-advisory relationships. Advisors retain sole responsibility for making all investment model selection and suitability determinations for their clients. If an advisor’s participation in such an arrangement creates a conflict of interest for them, that advisor is responsible for disclosing the conflict to their clients and explaining how they mitigate the conflict. We encourage all clients to read their investment advisor’s Form ADV and ask them about any conflicts of interest their investment advisor has and how they mitigate such conflicts. Item 15 – Custody The amended and revised Rule 206(4)-2 of the Advisers Act (the “Custody Rule”) sets forth extensive requirements regarding possession or custody of client funds or securities. The Custody Rule requires advisers that have custody of client securities or funds to implement a set of controls designed to 18  protect those client assets from being lost, misused, misappropriated, or subject to financial reverses. GeoWealth does not maintain direct custody or possession of any of its client’s funds or securities. However, because GeoWealth has the authority to deduct fees from client accounts, GeoWealth is deemed to have custody and complies with the requirements under Rule 206(4)-2 of the Advisers Act. These requirements are: 1) Advisers with custody of client funds and securities must maintain them with “qualified custodians.” Qualified custodians under the amended rule include banks and savings associations and registered broker-dealers. 2) If the Adviser with custody opens an account with a qualified custodian on behalf of the client, upon opening the account, the investment adviser must notify the client, in writing, of the qualified custodian’s name, address and how the funds or securities are maintained. 3) Advisers with custody must form a reasonable belief, upon due inquiry, that the qualified custodian maintaining the accounts holding the client’s funds or securities sends account statements directly to the client. 4) If the Adviser with custody also provides any other form of account statement to supplement the official account statements generated by qualified custodians, the Adviser must include a footer on the Adviser’s generated report urging the client to compare the investment adviser’s generated reports against account statements received from the qualified custodian. Through this arrangement, the custodians will provide, among other things, clearing, custodial, brokerage and record keeping services. Clients will receive statements from their qualified custodians at least on a quarterly basis. Clients are urged to compare the statements received by GeoWealth to the statements received by their qualified custodians. Item 16 – Investment Discretion For direct advisory relationships, prior to GeoWealth providing investment management services, the client will be required to fill out paperwork that sets forth the terms and conditions under which GeoWealth will advise on the client's assets. The client will also sign a separate custodial agreement with each designated custodian. Agreements with end clients include either discretionary investment services, non-discretionary services, or both. When GeoWealth has discretionary authority, GeoWealth is authorized, without prior consultation with the client, to: (i) buy, sell, exchange, and otherwise trade any stocks, bonds or other securities or assets and (ii) place orders and negotiate commissions (if any) for the execution of all transactions of securities with or through such broker-dealer underwriters or issuers as we, in our sole discretion, select. Any limitations to such authority must be communicated by the client to us in writing. Item 17 – Voting Client Securities 19  GeoWealth has established proxy voting policies and procedures pursuant to SEC Rule 206(4)-6 such that the CCO will oversee the proxy voting process. These procedures are designed to ensure that proxies are voted in the best interest of the clients and include the use of a proxy advisor firm. GeoWealth’s standard practice is not to vote proxies on behalf of clients. GeoWealth does not vote proxies unless your accounts are subject to a special arrangement with GeoWealth. If GeoWealth votes proxies for client accounts, GeoWealth will subject all securities in the client’s accounts to proxy voting regardless of whether or not the securities invested in managed models. GeoWealth’s standard proxy voting policy is designed to maximize returns. As designated by client’s investment advisor or manager and as agreed upon by GeoWealth, a limited number of other voting polices are available. In Models traded by SMA managers, the SMA manager has the option to vote any proxies received in accordance with their proxy voting policies and procedures, which are reasonably designed to ensure that they vote on securities in the best interest of clients. The SMA manager endeavors to vote proxies in accordance with the best economic interest of its clients and similarly to resolve any conflicts of interest exclusively in the best economic interests of the clients. In order to mitigate conflicts of interest, the SMA manager has contracted with an independent third-party service provider to vote proxies in accordance with instructions and guidelines provided or approved by the SMA manager. Clients should review the SMA manager’s Form ADV Part 2A Brochure for more information about their proxy voting policies. Where included in your investment management agreement with your primary adviser, SMA manager is also authorized to receive all proxy-related materials, annual and semi-annual reports, and other shareholder materials, including corporate actions, arising from any eligible investments or other securities in the account. You can receive a copy of these materials, the SMA manager’s proxy voting policy and procedures, voting guidelines and/or proxy voting record by submitting a written request to your primary adviser. If a client directs their qualified custodian to send proxies to GeoWealth and the account isn’t subject to a special exception whereby GeoWealth votes proxies, the client is indicating that they do not want to receive proxies, have no intention of casting a vote. GeoWealth requests that all clients either vote their own proxies, delegate proxy voting authority to their primary investment adviser, or delegate proxy voting authority to the separate account manager. If GeoWealth and the primary adviser and/or end client mutually agree that GeoWealth votes proxies on behalf of the client, GeoWealth’s voting decision will always be in the best interest of the client. If the client elects to vote proxies, applicable proxy information will be received directly from the client’s custodian or the respective transfer agent. GeoWealth shall not be responsible for delivering proxy documentation to clients. In certain circumstances, GWM may be appointed a sub-adviser to a client account and given proxy voting authority, GWM may, at its discretion, delegate its proxy voting authority to a 3rd party asset manager who has been appointed by GWM as a sub-adviser to the client Account. GWM will only appoint a sub-adviser to a client account, and thereby delegate proxy voting authority to that asset manager, at the Client’s primary adviser’s instruction. When we identify a material conflict of interest regarding a proxy that we have agreed to vote on behalf of client, we will always seek to resolve the conflict in the best interest of the client. One, 20  some, or all of the following steps may be taken: • Inform the client (or, in a sub-advisory relationship, the client’s investment adviser) of the material conflict • Discuss the proxy vote with the client or, in a sub-advisory relationship, the client’s investment adviser • Seek the client’s, or in a sub-advisory relationship, the client’s investment adviser, consent to vote the proxy as intended • Seek the recommendation of an independent third party Clients can obtain a copy of GeoWealth’s proxy voting policies and procedures upon request. Clients can also obtain information from GeoWealth about how they voted any proxies on behalf of their account(s). Clients who would like to obtain any information about how their proxies were voted, or wish to cast their vote in a particular way, should contact us at (312) 219-9160 or by email at evan.lieberman@geowealth.com. Item 18 – Financial Information GeoWealth does not require or solicit pre-payment of more than $1,200 in fees per client six months or more in advance, and as such has not included a balance sheet of its most recent fiscal year. Further, GeoWealth has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of bankruptcy proceedings at any time during the course of its business. 21 

GeoWealth Management, LLC Wrap Fee Program Brochure CRD # 148222 444 N. Michigan Avenue, Suite 3150 Chicago, IL 60611 November 2025 This wrap fee program brochure (the “Brochure”) provides information about the qualifications and business practices of GeoWealth Management, LLC (“GeoWealth” or “Firm”). If you have any questions about the contents of this Brochure, please contact us at (312) 219-9160 or by email at evan.lieberman@geowealth.com. You may also visit our website at www.geowealth.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. GeoWealth is a registered investment adviser. Registration of an Investment Adviser does not imply that GeoWealth or any of its principals or employees possess a particular level of skill or training in the investment advisory business or any other business. Additional information about GeoWealth is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes In July 2025, GeoWealth filed this brochure with the SEC. This amended brochure contains the following material changes. Item 6 has been updated to clarify that GeoWealth uses a proxy advisory firm to assist in voting proxies. When GeoWealth votes proxies for a client account, GeoWealth votes on all securities in the client account regardless of whether the securities are in a managed model. Item 9 has been updated to include that Apollo Management Holdings, L.P., has made an investment in GeoWealth. Further, GeoWealth, LLC, GeoWealth’s parent company, has entered into commercial partnerships with J.P. Morgan Asset Management, Apollo Management Holdings, L.P., Blackrock Investment Management. Item 9 has been updated to disclose that GeoWealth has entered into arrangements with certain third- party model managers, money managers, and alternative investment providers (“Third-Parties”) that allow advisors to access certain GeoWealth services either at no cost or at a reduced cost. For other Third Parties, GeoWealth receives compensation solely based on the assets invested in their products. 2  Item 3 – Table of Contents Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................... 3 Item 4 – Services, Fees and Compensation ........................................................................................................ 4 Item 5 – Account Requirements and Types of Clients .................................................................................... 7 Item 6 – Portfolio Manager Selection and Evaluation ..................................................................................... 7 Item 7 – Client Information Provided to Portfolio Managers ...................................................................... 14 Item 8 – Client Contact with Portfolio Managers ........................................................................................... 14 Item 9 – Additional Information ......................................................................................................................... 14 3  Item 4 – Services, Fees and Compensation Services GeoWealth operates a Turnkey Asset Management Platform (“TAMP”) and provides digital advisory tools that investment advisers rely on for managing their client accounts. In a TAMP, clients typically work directly with their primary investment adviser to determine their investment needs given their unique circumstances. The primary investment adviser then relies on GeoWealth to purchase and sell securities through the use of model portfolios and perform various other functions. This enables investment advisers to focus their efforts on the individual needs of their clients. Typically, advisers will engage with GeoWealth in a sub-advisory or co-advisory capacity, however in certain circumstances clients will work directly with GeoWealth. GeoWealth is able to provide not only investment management services, but GeoWealth can also handle the operational aspects of account opening and administration. These services include but are not limited to account opening and closing, interactions with the custodian, account maintenance, processing of contributions and withdrawals, Roth conversions/IRA recharacterizations, account transfers, quarterly billing and performance reporting. These services are typically provided to advisers under a co-advisory relationship. In a direct advisory relationship, GeoWealth, as an SEC Registered Investment Adviser, offers consulting and investment supervisory services on managed investment accounts to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, business entities and corporations (the “client” or “client account” or “end-client). For the small number of end-clients working directly with GeoWealth, the investment supervisory services include regular analysis and review of portfolios and advice concerning acquisition, retention, management, reinvestment and disposition of cash, securities and other assets of the client’s portfolios. When investing model portfolios, GeoWealth generally has the discretion to determine when to purchase or sell securities and whether to accept the recommendation of the model provider. It is GeoWealth’s standard practice to invest all model portfolios in accordance with the recommendation of the model provider but not a requirement. For end-clients who work directly with GeoWealth, we will work with the client to understand the client’s financial condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any restrictions on investing. Once the client’s investment portfolio has been designed and investments have been allocated, we will provide ongoing portfolio review and management services. Clients can place reasonable restrictions on their investment portfolio such as transferring in securities to be held long-term and not sold. Such restrictions must be provided in writing to, and accepted by, GeoWealth. Our model marketplace offers risk-based, thematic and outcome-based third-party models from industry-leading providers. Our model marketplace also offers access to alternatives and fixed income products which typically require additional enrollment paperwork. Through our TAMP and model universe, we ensure advisers have scalable solutions to respond to client needs. Additionally, we offer our own proprietary models and provide advisers with the ability to offer their own proprietary models which GeoWealth services on their behalf. Fees and Compensation 4  GeoWealth Management, LLC (“GeoWealth”) is the sponsor of the GeoWealth Wrap Fee Program which is offered to select clients at Charles Schwab and clients at Goldman Sachs Advisor Solutions. GeoWealth reserves the right to add other custodians at any time. The wrap program is designed to allow clients to pay a percentage of assets under management covering custody and trading fees such as commissions, transaction fees and handling fees. At Charles Schwab, the Wrap Fee covers Prime Brokerage, Step-In, Trade-Away Services, Exchange Process Fees, and mutual fund redemption fees. This fee structure replaces the typical fee structure whereby clients pay certain custodial fees on a per transaction basis. At Charles Schwab, the wrap fee does not cover, and therefore clients are responsible for paying the following: (a) Other Broker-Dealers’ Fees. Commissions and other fees for services provided by broker- dealers other than Schwab for transactions executed or effected by or through them that settle into or from Accounts, such as through Schwab’s Prime Brokerage, or Trade Away Services. Assets in Accounts that are purchased or sold through other broker-dealers will be included in the assets on which ABP Service Fees, if applicable, are assessed. (b) Mutual Fund Fees and Expenses. Fees charged by some mutual fund companies, unit investment trusts (UITs), closed-end funds and other collective investment vehicles, including, but not limited to, fees assessed by the fund but collected for the fund by Schwab such as sales loads (a portion of which are paid to Schwab) and/or charges and short-term redemption fees. (c) Markups and Markdowns, Bid-Ask Spreads, Selling Concessions, etc. Markups and markdowns, bid-ask spreads, selling concessions and the like received by Schwab in connection with transactions it executes as principal by selling or buying securities to or from clients for its own account. (d) Non-Publicly Traded Securities Custody Fees. Custody and setup fees for Non- Publicly Traded Securities (as defined in the Pricing Guide), which includes, without limitation, non- standard assets, non-publicly traded limited partnership interests, foreign securities and non- marketable securities. (e) Account Activity and Miscellaneous Fees. Fees and charges Schwab receives in addition to or other than commissions or ABP Services Fees in lieu of commissions, such as, but not limited to, margin interest, electronic funds and wire transfer fees and other account activity fees, transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, fees required by law, and any other similar costs or charges. (f) Advisory Fees. Fees charged by clients primary investment adviser for the investment advisory services they perform for you (g) Investment Management Fees. These fees are charged by model managers selected by each client’s primary investment advisor for the selection of securities in the selected investment model. At Goldman Sach Advisor Solutions, clients are charged fees according to the Special Services Fee Schedule which is published on their website which they can modify at their discretion. Clients also will be charged margin interest, if applicable, in accordance with the margin interest rate published on our website and updated from time to time. The Special Services Fees Schedule is located at https://www.folioclient.com/resources/service-fees.jsp. If a fee is not described as being covered by the Wrap Fee Program, clients are responsible for that fee. GeoWealth does not recommend any particular custodian to clients. Custodians are selected by each client. 5  Fees deducted from client accounts include an Advisory Fee, Platform Fee (Program Fee), and Investment Management Fee. The Advisory Fee is determined by your primary investment adviser for the investment advisory services they perform. The Platform Fee (Program Fee) compensates GeoWealth for providing investment management, custody and administrative services to client accounts and for the use of the GeoWealth platform. The Investment Management Fee varies based on the investment model selected by your investment adviser. Client investment management agreements may refer to these aforementioned fee types by different names, however they cover the same general categories of fees. Fee Schedules: Advisory Fee – Each client’s primary investment advisor sets the Advisory fee, and clients authorize GeoWealth to deduct the Advisory Fee from their custodial account. GeoWealth does not control what the fee will be. This fee is in addition to the wrap fee. Investment Management Fee – Each client may be charged Investment Management Fees based on the models selected by the primary investment advisor. This is in addition to the wrap fee. Platform Fee (Program Fee) – Each client pays GeoWealth a Platform Fee for use of the GeoWealth Platform and authorizes GeoWealth to deduct the Platform Fee from their custodial account. The Platform Fee is calculated as a percentage of the average daily balance of the Client’s Account in the prior month and is paid monthly in arrears. The Platform Fee paid by Client is the wrap fee. GeoWealth Platform Fee – UMA Models Unified Managed Account Models (“UMA Models”) provide the greatest choice and flexibility with access all in one account to separate account managers, exchange traded funds and mutual funds, including the ability to combine them in a number of ways to fit client needs. This includes access to 3rd party models, as well as advisor models from the built from same menu of models, investment strategies, funds, and securities as are available in 3rd party models. If a client or their primary investment advisor selects the UMA Model and an Account invests only in Fund Models, the percentage charged for purposes of the Platform Fee is still determined based on the UMA Model Program Fee scale. Client Household Assets at GeoWealth Annual Platform (Program) Fee <$250,000 0.30-0.83% Next $250,000 0.25-0.74% Next $1,500,000 0.20-0.70% Next $3,000,000 0.15-0.50% >$5,000,000 Negotiated GeoWealth Platform Fee – Fund Models 6  Fund Models consist solely of pooled investment vehicles of exchange traded funds (“ETFs”) or mutual funds sponsored and built by a select group of 3rd party model providers. Typically, a model is 100% ETFs or mutual funds but may combine ETFs and mutual funds. Multiple models may be purchased in one account. Client Household Assets at GeoWealth Annual Platform (Program) Fee <$250,000 0.25-0.40% Next $250,000 0.20-0.38% Next $1,500,000 0.18-0.36% Next $3,000,000 0.15-0.34% >$5,000,000 Negotiated The GeoWealth Wrap Fee Program may cost each client more or less than purchasing such services separately. Please refer to the Fees and Compensation section above which details the different factors that bear upon the relative cost of the program. Subject to an agreement with each client’s investment advisor, small accounts can be charged a minimum account fee, often times $12.50. Item 5 – Account Requirements and Types of Clients To participate in the GeoWealth Wrap Fee Program, your account must be held in custody at Goldman Sachs or be part of select relationships at Charles Schwab. GeoWealth reserves the right to expand the offering to other custodians and advisors at any time. Depending on our relationship with each client’s primary investment adviser, our relationship with the end client may be either through a sub-advisory agreement, co-advisory agreement, or direct advisory contract. End clients are generally individuals, high net worth individuals, trusts, family offices, corporations, and other business entities. GeoWealth does not have a minimum account size. However, to invest in certain models, there may be minimums imposed. Each client should inquire about any individual investment options with GeoWealth or their investment adviser. Item 6 – Portfolio Manager Selection and Evaluation GeoWealth’s Investment Solutions business is designed to provide flexibility and choice when it comes to investment management. GeoWealth offers financial advisers the ability to build and manage their own model portfolios (adviser-managed models), invest in third-party model portfolios, invest in GeoWealth’s own 7  proprietary model portfolios or UMAs, or designate third-party separately managed account managers (“SMA Managers”). A model is a collection of individual securities specifically chosen with the goal of achieving a particular investment objective. The decision about which model(s) to offer is made at the sole discretion of each client’s financial adviser. (1) “Adviser-Managed” Models: The financial adviser is the portfolio manager. These model portfolios consist of one or more investments in single stocks, ETFs and/or mutual funds. GeoWealth trades the model portfolios as directed by the financial adviser but has no investment discretion and does not choose the securities included in these models. (2) “Third-Party” Models*: A third-party asset manager or strategist is the portfolio manager, and the portfolio is traded by GeoWealth. Models can contain ETFs, mutual funds, stocks, bonds, structured notes, and alternatives. (3) GeoWealth Models: GeoWealth is the portfolio manager. We manage these portfolios using our own proprietary research and analysis processes. (4) Models traded by Third Party Managers *: A third-party investment adviser acts either as a sub-adviser or direct adviser over the account and makes all investment decisions in accordance with each end-client’s risk profile and investment objectives. SMA models can contain a broader range of securities, such as individual bonds and options. The SMA manager trades these models. (5) GeoWealth Unified Managed Account (UMA) portfolios: GeoWealth designs and constructs portfolios of “Third-party” and/or GeoWealth models. All components of the UMA are traded by GeoWealth. *In instances where GeoWealth uses an unaffiliated sub-adviser (SMA models) to manage the assets of an end-client, end-clients have the choice to receive the sub-adviser’s Form ADV Part 2A directly or have GeoWealth receive it on the end-client’s behalf. Unless instructed otherwise, GeoWealth will receive the sub-adviser’s Form ADV Part 2A on behalf of the end-client. GeoWealth regularly monitors all sub-advisers’ Form ADV Part 2A and will disclose any material conflicts of interest or concerns that we identify. Should an end-client want to view any sub-adviser’s Form ADV Part 2A, we remind them that they are available at https://adviserinfo.sec.gov/. 1) ADVISER MANAGED MODELS The adviser creates and manages their own model portfolio consisting of investments such as single stocks, ETFs, and/or mutual funds. The investment adviser uses their own independent analysis to determine which securities to invest client assets in and which models to offer to their clients. GeoWealth trades the models as directed by the financial adviser but has no discretionary investment authority over those assets. 2) THIRD-PARTY MODELS Third-party models offered in our model marketplace fall into three general categories: Tier 1, Tier 2 and Custom. GeoWealth conducts different levels of due diligence for models in Tier 1, Tier 2 and Custom. GeoWealth urges investment advisers to understand the level of diligence performed by GeoWealth and perform their own supplemental diligence such that they have a satisfactory understanding of the investment products and risks before recommending them to clients. GeoWealth collects an annual DDQ from all Tier 1 and Tier 2 managers. While performance information can be evaluated as part of the decision to offer an investment manager on the GeoWealth platform, performance is never a primary determinant. When we do obtain performance information, we obtain it from industry standard sources. Where possible, we 8  seek performance information is prepared in accordance GIPS® and follows SEC rule 206(4)-1. Tier 1 For all Tier 1 managers, GeoWealth obtains an understanding of the firm, investment offerings, investment philosophy and investment processes. Before onboarding and distributing Tier 1 models, GeoWealth collects and reviews a comprehensive due diligence questionnaire, ensures that each model manager is a registered investment adviser (RIA) and checks for any material regulatory disclosures in the ADV. This review is performed at the onset and again annually thereafter. Tier 2 Tier 2 models are designed to provide access to a broad range of managers and models. Before onboarding and distributing Tier 2 managers, GeoWealth collects and reviews a shortened due diligence questionnaire, ensures that each model manager is a registered investment adviser (RIA) and checks for any material regulatory disclosures in the ADV. Custom Third-party custom models operate differently than Tier 1 and Tier 2. Custom models may not be available to all investment advisers. In this scenario, the investment adviser and third-party asset manager collaborate directly through their own direct relationship with the model manager. The GeoWealth platform serves as the technology for delivering the custom models that the asset manager has developed directly with the investment adviser. GeoWealth is not responsible for any manager due diligence for custom models which must be performed by the client’s investment adviser. 3) GEOWEALTH MODELS GeoWealth offers our clients a broad range of proprietary models that invest in ETFs. Our models generally fall into the following categories: Strategic Risk-based, Income, Multi-Factor, Strategic Reserves, and Stable Return. Models may include ETFs that represent US stocks, international stocks, US fixed income, international fixed income, real estate, commodities, managed futures and more. • Strategic Models are a set of model portfolios across a risk continuum from conservative (higher allocation to fixed income or all fixed income) to aggressive (higher allocation to equities or all equities). Each model portfolio has a different risk profile to broadly align with an individual client’s risk profile. We also offer tax-sensitive versions of our strategic models. • Multi-Factor Models also use a strategic approach to asset allocation but have been built to emphasize factor exposure. Factors are characteristics shared by groups of securities that distinguish them from other securities. Examples include “value,” “size,” “quality,” and “momentum.” We have two sets of factor portfolios: one set utilizes factor-based funds from various mutual fund providers, and one set utilizes only Dimensional mutual funds. Dimensional Fund portfolios are only available to advisers who have been pre-approved by DFA. • The Short-Term Reserve Model is designed for investors who want to hold assets in a highly liquid form with relatively little downside risk. The portfolio is invested primarily in exchange-traded funds (ETFs) and/or mutual funds that invest in short-term fixed income 9  securities. Some of those funds will be designed to track indexes and others will be actively managed. • The Stable Return Model is a primarily fixed income ETF model that dynamically allocates across a diversified spectrum of income‐producing asset classes. The model is updated monthly based on a systematic process. • Tactical Models These risk-based portfolios range from conservative to aggressive across five risk tolerance profiles. They are primarily composed of actively managed SMA strategies, ETFs, and mutual funds. The managers have discretion to dynamically shift allocations across and within equity and fixed income asset classes based on their market outlooks. These portfolios are designed to reflect real-time tactical views, offering flexibility to adjust exposures in response to changing market conditions. • Strategic / Tactical Hybrid Models These portfolios combine long-term strategic asset class exposures with tactical flexibility. They include dedicated SMAs that provide consistent exposure to core asset classes, while layering in tactical SMA strategies that allow for dynamic asset allocation across equity and fixed income. This hybrid approach balances the stability of strategic positioning with the agility of manager-driven tactical shifts. • Income Models These portfolios are designed to generate income across five risk-based profiles, from conservative to aggressive. The construction blends strategic exposures to income-generating asset classes with tactical SMA strategies that allow for dynamic allocation within fixed income. Tactical components provide flexibility to adjust to changing market conditions and yield opportunities, while strategic sleeves offer consistency and long-term income stability. • Sector Models These portfolios take a hybrid approach, combining strategic allocations to core sectors with tactical SMA managers who express sector-specific views based on their market outlook. The structure enables managers to overweight or underweight sectors dynamically, while maintaining baseline exposures that reflect long-term strategic positioning. The result is a model designed to capitalize on sector rotation opportunities while remaining anchored in a diversified sector framework. GeoWealth’s Investment Solutions team is responsible for selecting ETFs within the GeoWealth model portfolios. Our due diligence processes use both quantitative and qualitative factors. Index- weighted ETF selection is mostly quantitative. We also use actively managed ETFs within some of our model portfolios; these funds are not index-tracking and their performance can differ substantially from that of traditional market-cap-weighted indexes. Active ETF fund selection can have a heavier qualitative assessment on the strength of the portfolio management team. 4) MODELS TRADED BY THIRD PARTY MANAGERS A third-party asset manager acts either as a sub-adviser or direct adviser over the account and makes all investment decisions in accordance with each end-client’s risk profile and investment objectives. For Index Portfolios (also known as direct indexing), the adviser provides relevant information to the asset manager to create an investment strategy that takes into consideration various client specified constraints and preferences, while seeking to quantify and minimize the tracking error to a defined index (or blend of indexes). An Index Portfolio is made up of individual stocks and includes, but is 10  not limited to ESG/Impact customization, factor tilts, single-stock exclusions/inclusions, and regional constraints. 5.) GEOWEALTH UMA (UNIFIED MANAGED ACCOUNT) PORTFOLIOS GeoWealth designs and constructs portfolios of “Third-party” and/or GeoWealth models. All components of the UMA are traded by GeoWealth. The current GeoWealth UMAs invest in third-party and GeoWealth models selected by the Investment Solutions Team. Underlying models may include ETFs and stocks that represent US equity, international equity, US fixed income, international fixed income, real estate, commodities, managed futures and more. Risk of Loss Factors Investing in securities involves risk of loss that clients should be prepared to bear. Clients may lose some or all of their principal and generate less income than anticipated or no income at all. In general, risks include: market risk, interest rate risk, issuer risk, liquidity risk, and general economic risk. Although we manage the assets in a manner consistent with risk tolerances, there can be no guarantee that the future anticipated performance of any investment will occur. There is also a risk that the portfolios will not achieve their specific investment objectives. There is a risk that index-oriented funds included in portfolios will not precisely track the performance of the indexes they are intended to replicate. The following are material risks related to our investment strategies. This list does not purport to be a complete enumeration or explanation of every possible risk associated with our investment strategies. Equities The risk that events negatively affecting issuers, industries or financial markets in which an underlying fund or separate account invests, will negatively impact the value of the stocks held. Fixed Income The risk that fluctuations in interest rates or events negatively affecting the issuers, industries or financial markets in which the security is exposed to will cause the value of fixed-income securities held to decline. Alternatives Alternative investments take on many forms and each private investment has its own risk of loss factors. In general, alternative investments lack the transparency of other investment types, have less regulatory reporting requirements, are illiquid, and have special tax considerations, among other risks. International Securities The possibility that international stocks may be adversely affected by political and social instability, changes in economic, governmental or taxation policies, difficulty in enforcing regulations or claims, decreased liquidity or increased volatility. 11  Small to Medium Capitalization Companies GeoWealth may invest a portion of client assets in the stock of companies with small to medium- sized market capitalizations. While GeoWealth believes these investments often provide significant potential for appreciation, those stocks (particularly smaller-capitalization stocks), involve higher risks in some respects relative to investments in stocks of larger companies. For example, prices of such small-capitalization stocks are often more volatile than prices of large-capitalization stocks. In addition, if the stock is not traded frequently, there is a chance that the purchase price or sale price will be impacted by the lack of liquidity. Lack of Diversification Client portfolios may not be widely diversified among sectors, industries, geographic areas or types of securities. Further, client portfolios may not necessarily be diversified among a wide range of issuers. Accordingly, the portfolios will be subject to more rapid change in value than would be the case if the portfolio was highly diversified. Portfolio Turnover Depending on the investment strategy selected, it is possible that GeoWealth will need to trade in and out of securities frequently. If the investment strategy selected requires this, transaction-related charges may negatively impact the portfolio return. Short-Sales GeoWealth may affect short sales. Short sales can, in certain circumstances, substantially increase the impact of adverse price movements on a portfolio. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, which could result in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Leverage While not typical, GeoWealth may trade on margin or engage in other forms of borrowing to affect the purchase of securities in a portfolio. The level of interest rates and the rates at which client accounts can borrow will affect their returns. Fluctuations in the market value of the portfolio of a heavily leveraged account can have a disproportionately large effect on the account value. For more information regarding the specific risks that are associated with a particular investment, clients are encouraged to consult the offering documents or similar disclosures. Related Person Disclosures As explained above in items 3 and 5, GeoWealth constructs some of its own models that are offered on the GeoWealth platform. We are required to disclose to you that the portfolio managers of these models are employees of GeoWealth and are therefore considered related persons. To ensure that this does not create a conflict of interest, GeoWealth models are provided as just one of many different investment offerings on the GeoWealth platform. Advisors are free to choose any investment model they desire— GeoWealth does not make the choice for them. Securities within the GeoWealth models are all issued by 3rd parties and GeoWealth is not compensated for their inclusion. 12  Performance-Based Fees and Side-By-Side Management Neither GeoWealth nor any of our supervised people accept performance-based fees. Voting Client Securities GeoWealth has established proxy voting policies and procedures pursuant to SEC Rule 206(4)-6 such that the CCO will oversee the proxy voting process. These procedures are designed to ensure that proxies are voted in the best interest of the clients and include the use of a proxy advisor firm. If GeoWealth votes proxies for client accounts, GeoWealth will subject all securities in the client’s accounts to proxy voting regardless of whether or not the securities invested in managed models. GeoWealth’s standard proxy voting policy is designed to maximize returns. As designated by client’s investment advisor or manager and as agreed upon by GeoWealth, a limited number of other voting polices are available. In Models traded by SMA managers, the SMA manager has the option to vote any proxies received in accordance with their proxy voting policies and procedures, which are reasonably designed to ensure that they vote securities in the best interest of clients. The SMA manager endeavors to vote proxies in accordance with the best economic interest of its clients and similarly to resolve any conflicts of interest exclusively in the best economic interests of the clients. In order to mitigate conflicts of interest, the SMA manager has contracted with an independent third-party service provider to vote proxies in accordance with instructions and guidelines provided or approved by the SMA manager. Clients should review the SMA manager’s Form ADV Part 2A Brochure for more information about their proxy voting policies. Where included in your investment management agreement with your primary adviser, SMA manager is also authorized to receive all proxy-related materials, annual and semi-annual reports, and other shareholder materials, including corporate actions, arising from any eligible investments or other securities in the account. You can receive a copy of these materials, the SMA manager’s proxy voting policy and procedures, voting guidelines and/or proxy voting record by submitting a written request to your primary adviser. If a client directs their qualified custodian to send proxies to GeoWealth and the client agreement directs GeoWealth not to vote proxies, the client is indicating that they do not want to receive proxies, and have no intention of casting a vote. GeoWealth requests that all clients either vote their own proxies, delegate proxy voting authority to their primary investment adviser, or delegate proxy voting authority to the separate account manager. If GeoWealth and the primary adviser and/or end-client mutually agree that GeoWealth votes proxies on behalf of the client, GeoWealth’s voting decision will always be in the best interest of the client. If the client elects to vote proxies, applicable proxy information will be received directly from the client’s custodian or the respective transfer agent. GeoWealth shall not be responsible for delivering proxy documentation to clients. In certain circumstances, GWM may be appointed a sub-adviser to a client account and given proxy voting authority, GWM may, at its discretion, delegate its proxy voting authority to a 3rd party asset manager who has been appointed by GWM as a sub-adviser to the client Account. GWM will only appoint a sub-adviser to a client account, and thereby delegate proxy voting authority to that asset manager, at the Client’s primary adviser’s instruction. GWM utilizes the services of Broadridge and a proxy advisory firm to facilitate proxy voting for accounts GWM has accepted proxy authority over. Clients must understand that if GeoWealth has 13  proxy voting authority over an account (whether or not securities are invested in an investment model), GeoWealth will vote all securities in that account in accordance with our proxy voting policy. When we identify a material conflict of interest regarding a proxy that we have agreed to vote on behalf of client, we will always seek to resolve the conflict in the best interest of the client. One, some, or all the following steps may be taken: • Inform the client (or, in a sub-advisory relationship, the client’s investment adviser) of the material conflict • Discuss the proxy vote with the client or, in a sub-advisory relationship, the client’s investment adviser • Seek the client’s, or in a sub-advisory relationship, the client’s investment adviser, consent to vote the proxy as intended • Seek the recommendation of an independent third party Clients can obtain a copy of GeoWealth’s proxy voting policies and procedures upon request. Clients can also obtain information from GeoWealth about how they voted any proxies on behalf of their account(s). Clients who would like to obtain any information about how their proxies were voted, or wish to cast their vote in a particular way, should contact us at (312) 219-9160 or by email at evan.lieberman@geowealth.com. Item 7 – Client Information Provided to Portfolio Managers Except as otherwise agreed in writing or as required by law, GeoWealth will keep confidential all private information concerning client identity, financial affairs and investments. All information provided by GeoWealth and all recommendations and advice furnished to client by GeoWealth shall be regarded by each as confidential. GeoWealth shall exercise the highest degree of due diligence and care with respect to any and all information relating to Client that comes into our possession. Please read GeoWealth’s Privacy Policy, which has been separately provided, for more details about our privacy practices. Item 8 – Client Contact with Portfolio Managers GeoWealth is readily available to address questions or concerns regarding any investments made in their accounts. A client will not be able to communicate directly with any Manager or Model Provider available through our Platform. Clients should communicate any changes in investment objectives and restrictions as well as changes in financial condition to GeoWealth or their financial advisor who will then provide that information to GeoWealth. Item 9 – Additional Information Disciplinary Information GeoWealth does not have any disciplinary information to disclose in this section. Specifically, there were no criminal or civil actions, administrative enforcement proceedings, or self-regulatory organization enforcement proceedings to be disclosed. 14  Other Financial Industry Activities and Affiliations JPMC Strategic Investments Group I Corporation (an affiliate of J.P. Morgan Asset Management), Apollo Management Holdings, L.P., and Blackrock SMI, LLC(an affiliate of Blackrock Investment Management), each own a minority interest and have commercial partnerships with GeoWealth, LLC, GeoWealth’s parent company. As part of its own due diligence, GeoWealth annually reviews securities for inclusion in its own model portfolios. J.P. Morgan Asset Management, Blackrock Investment Management, and Apollo Management, as well as other asset managers, are eligible to receive placement in GeoWealth’s models based upon our own due diligence. Please see Item 14 – Client Referrals and Other Compensation which discusses conflicts of interest relevant to the placement of these securities in GeoWealth models. GeoWealth entered into an agreement with 55 Institutional Partners, LLC (“55IP”) to provide tax-loss harvesting, tax-aware transitions, tax aware withdrawals, and other tax conscious portfolio management solutions. 55IP is a wholly owned subsidiary of J.P. Morgan Asset Management whom, as explained above, owns a minority interest in GeoWealth, LLC. GeoWealth does not receive any compensation for offering any of 55IP’s services. Effective March 31, 2023, GeoWealth Management LLC’s (“GeoWealth”) parent company, GeoWealth, LLC, acquired First Ascent Asset Management, LLC (“FAAM”). FAAM was an investment adviser registered with the SEC. Effective March 22, 2024, GeoWealth took over the investment advisory business of FAAM and all FAAM clients are now investment advisory clients of GeoWealth. Effective August 1, 2025, GeoWealth’s parent company, GeoWealth, LLC, acquired a majority of TAMP assets from Freedom Advisors. Participation or Interest in Client Transactions Employees of GeoWealth can own securities in their personal accounts that are also recommended by GeoWealth. The Firm has established procedures intended to limit conflicts of interest in cases where GeoWealth or any of their employees buys or sells securities recommended by GeoWealth to our clients. GeoWealth does not engage in principal trading and does not recommend securities to advisory clients it has a proprietary or ownership interest in. However, subject to GeoWealth’s Code of Ethics, employees may purchase and sell securities either recommended by GeoWealth or held in models maintained on the GeoWealth platform. Code of Ethics & Personal Trading Pursuant to Rule 204A-1 of the Advisers Act, GeoWealth has adopted a Code of Ethics that establishes how we hold ourselves out as having a high standard of ethical conduct and how we serve as a fiduciary to our clients. Key aspects of our code of ethics include handling conflicts of interest, gifts and entertainment, political contributions, employee trading, privacy, and insider trading, among other items. GeoWealth recognizes and believes that (i) high ethical standards are essential for its success and to maintain the confidence of its clients; (ii) its long-term business interests are best served by adherence to the principle that the interests of clients come first; and (iii) it has a fiduciary duty to its clients to 15  act solely for the client’s benefit. All GeoWealth employees must put the clients’ interests before their own personal interests and must act honestly and fairly in all respects in dealings with clients. All GeoWealth employees must also comply with all federal securities laws. In general, employees (and members of their immediate households) must obtain written pre- approval from the Chief Compliance Officer (“CCO”) or their delegate prior to executing a personal transaction in equity securities, ETFs, options, and futures. The spirit of the Code of Ethics is to discourage frequent trading in employee personal accounts. In addition, employees must receive pre-approval from the CCO or their delegate to acquire securities for their own account in an initial public offering. Employees must also obtain pre- approval from the CCO or their delegate before engaging in any outside business activities or private placements. Certain highly liquid index tracking ETFs do not require pre-approval. All employees must provide duplicate copies (when available) to the CCO or their delegate of brokerage statements for accounts over which the employee has discretion. These records are used to monitor compliance with the foregoing policies. Employees must also annually attest to the location of their holdings. These policies apply to any personal transactions involving certain equity, debt, options, and futures (or derivative products related to these securities). This policy does not apply to transactions involving government securities, open-end mutual funds, or other instruments which afford the investor no discretion over individual securities transactions. GeoWealth strictly prohibits the misuse or inappropriate communication of inside information in connection with securities transactions. GeoWealth, as well as federal and state securities laws, also prohibit the practice of market manipulation (defined as action intended to deceive or defraud investors by controlling or artificially affecting the price of securities). In special situations, GeoWealth will create an information barrier or a “Chinese Wall” procedure that restricts the disclosure of confidential information to those who have a genuine “need to know”. The Firm has also adopted communications guidelines designed to assist personnel in understanding their duties and responsibilities regarding the receipt and the communication of financial and other sensitive information. GeoWealth restricts the giving and receiving of gifts, limiting participation in and sponsoring of entertainment events, and requires the reporting of gifts and entertainment to the CCO or their delegate subject to certain exceptions. GeoWealth also has a policy that governs political contributions to certain officials and political parties. This policy is designed, among other things, to address the requirements of Rule 206(4)-5 under the Advisers Act. Our Code of Ethics is available upon request. Review of Accounts All client accounts in a direct advisory relationship with GeoWealth are reviewed on at least an annual basis to ensure conformity with Client objectives and guidelines unless the client and adviser mutually agree otherwise. These accounts are regularly monitored in response to changes in investment objectives by the client or as deemed appropriate in light of market conditions. For all accounts, we periodically review them to ensure consistency with the trading instructions received. Reviews are performed by members of GeoWealth’s trading team whose compliance with SEC rules and regulations is ultimately overseen by the CCO. Generally, clients will receive detailed account reports from GeoWealth or each client’s investment 16  adviser on a monthly or quarterly basis via electronic delivery. These reports are supplemental to the statements provided by each client’s qualified custodian. A standard reporting package includes a performance summary, holdings summary, and a fee summary. Each client’s primary investment adviser has the ability to change which reports are provided based on the unique needs of the client and/or adviser. Client Referrals and Other Compensation GeoWealth has entered into arrangements with certain third-party model managers, money managers, and alternative investment providers (“Third-Parties”) that allow advisors to access certain GeoWealth services either at no cost or at a reduced cost. Under these arrangements, the Third Parties compensate GeoWealth for the advisor’s use of the GeoWealth platform. For other Third Parties, GeoWealth receives compensation solely based on the assets invested in their products. The list of Third-Parties changes from time to time and is available upon request. These payments can take the form of either (i) a fee paid by the Third-Party to GeoWealth to offset the fees that GeoWealth would otherwise charge advisors, or (ii) a payment based on a percentage of assets in Third Parties products, or both, and can be subject to minimums. Whenever GeoWealth receives compensation directly from a Third Party, a conflict of interest arises because GeoWealth is incentivized to promote Third Parties that result in greater compensation to GeoWealth than other investment options. Although this conflict exists, GeoWealth does not have the authority to select investment models for clients within co-advisory or sub-advisory relationships. Advisors retain sole responsibility for making all investment model selection and suitability determinations for their clients. If an advisor’s participation in such an arrangement creates a conflict of interest for them, that advisor is responsible for disclosing the conflict to their clients and explaining how they mitigate the conflict. We encourage all clients to read their investment advisor’s Form ADV and ask them about any conflicts of interest their investment advisor has and how they mitigate such conflicts. Please see Item 4 – Services, Fees and Compensation for information. ERISA When we provide investment advice to Clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with our clients’ interests, so we operate under a special rule that requires us to act in our clients’ best interest and not put our interest ahead of yours. Under this special rule, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; 17  • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. 18